privacy policy

INTRODUCTION

Emek Tech LLC, and their subsidiaries and parent companies (collectively, “Emek Tech”, “we”, “our,” or “us”) is a social gaming company that creates, produces, and distributes products and services for players worldwide.

This privacy policy (the “Privacy Policy”), explains how we collect, use and share data through our mobile applications (collectively, “Applications”, “App(s)”), our websites (the “Websites”), our pages or presence on third party websites (e.g., Twitter, Instagram, Facebook,) (the “Third Party Platforms”) and other platforms, websites products, offers and services that we offer from time to time, all of which together we refer as “Services” or “Service”.

In this Privacy Policy, “Emek Tech LLC” refers to Emek Tech, and its “Affiliates”, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We may also refer to Emek Tech LLC as "we" or "us".

If you do not want Emek Tech to collect, store, use, or share your personal information in the ways described in this Privacy Policy, you may not play our games or use our Services.

Our Privacy Policy applies whenever you use our “Services” which, as we described above, means our games, products, services, content, our websites, and/or other domains or websites operated by Emek Tech. It describes the ways we use your data and your rights.

We refer to countries in the European Union (EU) and the European Economic Area (EEA) and Switzerland collectively as the “European Countries” in our Privacy Policy.

This Privacy Policy applies when you use any of our Services. Please read and acknowledge that you accept our Privacy Policy and Terms of Use by using our Services.

Children

Please note that our games are not meant for children under the age of 16 and we do not knowingly collect any personal information from children under 16. Children under 16 should not use our services at any time. If we learn that we have inadvertently gathered personal information from a child under 16, we will take reasonable measures to promptly remove that information from our records. If you become aware of any data we have collected from children under the age of 16, please contact us at your earliest convenience.

HOW WE COLLECT DATA

We will collect and store any data that you provide to us.

1. YOUR DATA

While you use our games, you may give us data directly and we will store that data on our databases and use it for the purposes described in this Privacy Policy.

When you use our games, you give us specific data such as:

• first and last name
• age
• e-mail address; or
• other information that helps improve our services or makes it easy for you to access our Services

You may also create a player profile in our game which other players may see, and which may include the data like:

• profile photo
• first and last name
• nickname
• gender
• age
• physical location data that you provide
• player ID used to identify you and created by us

2. YOUR INFORMATION

We may collect information that you provide to us about your Facebook Friends’ List; however, we ask permission before we do so.

3. DATA GENERATED

We collect data about the ways in which you use and interact with our games (e.g., when and for how long you play, game features and other players you interact with, purchases you make, progress or levels you achieve, and other gameplay activities). If you choose to use communication features in Services that allow you to communicate or share information with other players, then Emek Tech will collect information on what is communicated or shared. This may include your in-game actions like:

• participation in player groups or events
• public posts or comments on sent to other players
• non-public messages or invitations to other players
• chats with other players

Please understand that we reserve the right to access such communications and generated data, and/or store archives of these communications, comments, and other user-generated content on our servers to make use of them to protect the safety of our players. We do so to protect our rights and property in connection with our Services; to conduct research; evaluate, improve, and personalize our Services and our players’ experiences, including but not limited to the use of analytics; and to manage and deliver specific advertising. Where required, we will seek consent for this.

4. PAYMENT DATA

We collect data related to any purchases you make.

When you purchase in-game virtual currency, our third-party payment partners will collect the necessary billing and financial information required. Please note that this may include your home address, e-mail, and other pertinent financial data. Understand that our partners do not share any of your financial information, such as credit card numbers, with us, but they may share other data related to your purchases, like your name, and the items purchased. When you play our games connected third-party applications or platforms (like Facebook, Apple or Google), 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, Emek Tech does not receive your financial data, but may receive non-financial information related to your purchases, like your name and the items purchased. The information we receive depends on our game you are playing and the third-party application. Our Terms of Use explain our policies and terms related to charges, billing, third-party credits, and virtual currencies. Please note that purchases of third-party credits or currencies are also subject to those parties’ terms of service and privacy policies.

5. SUPPORT TEAM

By contacting our Support Team (“Support”), you authorize us to collect and store the contact information you give them (generally, your name, e-mail address, player ID), along with any data about your game play or your activity in a game.

We will store the communications you have with our support and any additional information in those communications in order to provide support and improve the Services. In order to identify you, we will need certain information from you (e.g., player ID). Please be aware that we may contact you and request additional information in order to provide effective support.

When you contact us for support, the below information may be asked of you:

• game you are playing
• name or nickname
• e-mail address
• platform you are playing on
• problem description
• language
• player ID or
• Facebook ID.

Notice we also collect additional types of data, such as your IP address and data sent by your device to provide and improve our service. As a safeguard to protect your privacy, we arranged a data processing agreement with our partners where we ensure that your personal information is only used in accordance with our instructions and not for their own purposes or are used in accordance with the applicable law requirements or our contractual arrangements with our partners. Your request is sent via an encrypted connection and we collect only such data that is actually required to best answer your request. The content of your request will be stored as long as you are an active player of our game, so you can get a faster response in case you have a similar problem in the future.

6. HOW WE COLLECT COOKIES

We collect information about your device and how you use our Services using cookies.

We use cookies to recognize you and/or your device(s) across different Services and devices. You can control or opt out of the use of cookies and similar technologies.

We use cookies and other similar technologies to collect and analyze certain kinds of technical data, including:

• IP address
• type of computer or mobile device you are using
• platform type (like Apple iOS or Android)
• operating system version
• mobile device identifiers, like your MAC Address, Apple Identifier for Advertising (IDFA), Android Advertising ID (AAID), Google Advertising ID (GAID)
• browser type and language
• number of clicks on an app feature or web page
• amount of time spent on an app feature or web page
• game state and the date and time of activity on our game

If you play our games on a mobile device, in addition to your device identifiers (described above), we may also collect:

• name of your device
• country
• telephone number (with permission)
• specific geolocation (with your permission)
• mobile contacts (with your permission)

7. THIRD-PARTY DATA

We collect information from entities like Facebook, if you access our games through your accounts with those entities or you choose to connect your accounts with such companies to our games.

If you play our games through any third-party applications, including Facebook, we may receive certain data about you from the provider of the third-party application. The information we receive depends on our game you are playing, the third-party application, your privacy settings, and, if applicable, your friends’ privacy settings on that third-party application. We may collect and store some or all of the following information:

• first and last name
• profile picture
• your user ID (Facebook ID)
• your friends’ list and other public data
• e-mail address
• physical location of devices used to access our Services
• age
• information about your activities on or through the connected third-party application
• other publicly available data on the third-party application; and/or

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 use and their privacy policy.

8. OTHER DATA

We may collect data from other third-party sources. Where we do, we let you know.

We may collect or receive data about you from other sources like third-party data providers. We use this data along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.

9. USE OF DATA AND LEGAL GROUNDS FOR PROCESSING

We use your data to provide, personalize, maintain the security of, and improve the games you use; to maintain our business operations; and to exercise, defend or establish our rights.

We use your data under several legal grounds, including:

• contractual obligations
• legitimate business interests
• to comply with legal obligations
• your consent

The data we collect, and store is to provide you with the Services you request from us and to improve your in-game experience, but there are other uses as well. The uses for which we collect and store your data include:

• to improve and optimize our games and your experiences in our games
• to create your player accounts and allow you to play our games
• to protect your safety
• to communicate with you, including in-game updates and notifications, new Services, and promotional offers that we think might be of interest to you
• to enable players to communicate with each other
• to provide support and respond to player requests
• to protect our rights and property in connection with our games
• to prevent fraud or potentially illegal activities, and to enforce our Terms of Use
• to manage and deliver customized advertising
• to administer promotional activities or events sponsored or managed by us or our partners
• to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties.

Note that we normally collect data from you only where we need it to perform our contract with you (i.e., pertaining to our Terms of Use), where the processing is in our legitimate interests or if you give us your consent.

In some cases, we may also have a legal obligation or need to collect data from you or may otherwise need the personal data to protect your vital interests or those of another user. If we ask you to provide data to comply with a legal requirement or to perform a contract with you. We will also make clear whether providing data is mandatory.

10. DATA SHARING

We share some of your data with your friends and other players that you are playing with to facilitate your in-game interactions. We may also share your data with third parties or allow third parties to collect this information from our games in the following manner:

11. OTHER PLAYERS

Your friends who play our game will see your name, photo, player profile and descriptions of your in-game activity. Other players will be able to see your player profile; view descriptions of your in-game activity; communicate with you within our games and send you game requests or friend requests through our games.

12. ADVERTISING

We share some of your data with advertisers to tailor the advertisements you see when you use our Services to your interests and to enable us to offer some of our Services for free.

We use advertising to enable us to offer some of our games for free. These advertisements may include, without limitation, banner ads on in a game, as a full-screen ads between moves or games in which third-party advertisers offer to provide in-game items to players in exchange for watching an advertisement or for completing a task.

We do not actively share personal data that directly identifies you with third-party advertisers for their direct marketing purposes unless you give us your consent.

To enable advertisers and ad media partners to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of data when you use our games:

• performance data
• technical information (IP address, IDFA, Apple ID, Google ID)
• a unique identifier, (e.g., Facebook ID or player iD)

The data collected may be used to:

• offer you targeted advertising in order to personalize your experience
• undertake web analytics to analyze traffic and other player activity to improve your experience.

Ad networks may collect this data through the use of cookies and other similar tracking technologies.
Please understand that after clicking on a third-party advertisement, you may no longer be on a site or app controlled by us through which you are playing our games. The practices of third-party companies delivering advertisements in our games are subject to those companies’ own privacy policies.

13. SECURITY

We share your data if necessary, for safety, security, or upon request or reasonable compliance with law. Your data and the contents of all of your online communications in our games may be accessed and monitored as needed:

• to satisfy any laws or regulations
• in response to lawful requests by public authorities
• companies and organizations for the purposes of fraud protection and other security precautions
• to protect our property rights

14. 3RD PARTY SERVICE PROVIDERS

We share your data with the third-party service providers and partners that we work with.
We will share your information with third-party companies who perform services on our behalf. These services may include but are not limited to analytics, analysis, hosting services, customer service, marketing, and advertising optimization.

We will also share your data with our third-party partners who assist us in delivering and optimizing our Services (e.g., Apple, Google, Facebook, Amazon, etc.). Note that if we share your data with third-party service providers and partners, we ensure that we have appropriate agreements in place to protect your information.

15. OTHER PARTIES

We may share some of your information with other third parties, if we have your consent to do so. In addition to the sharing described above, we may share your data with other third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy if we have your consent to do so.

16. DATA SUBJECTS’ RIGHTS

A. European Countries ‘Players’ Rights

If you are located in the European Countries, you have the following rights:

• You can access or delete your personal information by submitting a request through the Support link within our Applications.
• You can opt-in or opt-out of marketing communications we send you by following the necessary instructions.
• If we have collected and processed your personal information with your consent, then you may withdraw your consent at any time through the settings within our Applications.

We respond to all data protection requests we receive in accordance with applicable data protection laws.

B. ACCESSING AND DELETING PERSONAL DATA

You can request a copy of or deletion of your game account data through our game via our Support team.

To review and update personal data (including given us any consents) associated with your player profile in certain games, visit “Settings” within the Application. If you want to review or delete your game account, please submit a request through the Application itself or through our support. We will keep certain records (e.g., personal data relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We will also keep data in order to exercise, defend, or establish our rights.

C. MANAGING YOUR DATA

In order to manage information, we receive from third-party applications and from your mobile device, use the settings provided by the third-party application and your mobile device. Once we receive your data from a third-party App or your mobile device, that data is stored and used by us in accordance with this Privacy Policy. You may access and update that information as described above.

17. MARKETING COMMUNICATIONS

You can unsubscribe from our promotional emails by clicking the “unsubscribe” link. Also, you can opt out of mobile push notifications in your specific mobile device’s settings page.

If you want to stop receiving push notifications, you can turn off push notifications by visiting your mobile device’s “Settings”.

Please note that if you opt in or out of receiving marketing communications from us, we may still communicate with you from time to time if we need to provide you with information about the games you are using from us, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons.

18. THIRD-PARTY ADVERTISING AND COMMUNICATIONS

While you give us your consent for obtaining the personalized advertising from our third-party partners, you can opt in or opt out of third-party customized advertising through your device Settings and other opt-in or opt-out tools. If you do not want to receive tailored in-application advertisements from third parties that relate to your interests on your mobile device, you may elect to opt-out through the third parties respective opt-out feature. Based on the platform provider (such as Apple or Google), you may be able to download apps that provide you with control regarding the collection and use of cross-app data for tailored advertising. All of the opt-in or opt-out tools described in this subsection are provided by third parties, not by us. Please note that you may still receive third-party advertisements in our games after using the thoird-party tools, but the advertising you see would not be customized to your interests or needs.

19. PRIVACY POLICIES OF LINKED THIRD-PARTY SERVICES

We are not responsible for the ways in which third parties use your data (other than our partners acting under our guidance). Our websites and games may contain advertisements from third-party services that may link to their own websites or services. Please understand that we are not responsible for the privacy practices or the content displayed by these parties.

20. CHILDREN’S ONLINE PRIVACY PROTECTION RULE

Please understand that our games are not intended for children under 16 years old. We do our best to ensure that we do not collect information from child. Children under 16 are not permitted to use our games, and we do not knowingly collect any personal data from Children. Though our Services do not target Children, we may collect age information before allowing a player to proceed for certain games. If we allow children under 16 to use the games or our services, we will either provide a version of that games that does not collect, use, or disclose “personal data” (as defined per the Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA or obtain legally valid legal guardian consent. If we learn that we have inadvertently gathered personal data that is not subject to a COPPA exception from a child under 16, we will take reasonable measures to promptly remove that information.

21. TRANSFER OF DATA

When you use our games, your personal data may be sent outside of Europe and to other countries like the US, China, etc. We comply with our legal obligations and ensure that your personal data is subject to suitable safeguards (such as encrypting communication) or transferred to “approved” territories. We store personal data about players and visitors to our sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. The data we have access to may be processed by employees operating outside of the European Countries who work for us. This staff may be engaged in, among other things, marketing communication with players and product development. When we transfer your personal data we will take reasonable steps to ensure that your data secure and transferred in a lawful way.

22. DATA RETENTION

Note that we keep your information to provide you with the Services, maintain our legitimate business operations and defend or establish our rights. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements. We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. You acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to defend or establish our rights.

23. SECURITY OF YOUR INFORMATION

We implement reasonable and appropriate security measures to help protect the security of your data and to ensure that your data is treated securely and in accordance applicable laws. It is important that you protect and maintain your account’s security and that you immediately tell us of any unauthorized use of your account, including but not limited to any hacking attempts or false logins. If you access our Services through Facebook and your account is hacked or otherwise compromised, this may lead to someone accessing or deleting your game accounts without your permission.

24. PUTTING YOUR ACCOUNT ON HOLD

If at any point in time you become concerned about your gaming behavior or you would like to take a break from the game, you can contact our Support team and request to have your device banned from the game for a specific amount of time. You can choose to take time off by requesting that we block your device’s access to our game for a minimum period of one year (or longer at your request). During this block time, you will not be able to play our game on all platforms from all of your accounts. If you send us a request to block your account through the game, we will be able to ban your device and any other devices that are connected to this account’s player ID. During the time off period, the blocked access will be enforced and but can be revocable upon your consent. Understand that if you accept push notifications on your devices and internet browsers or download any of our applications to your device from the Apple AppStore or directly from our website to your device and you accept to receive push notifications, we will not be able to block receipt of such notifications even if you request to block your account. The only way to prevent receipt of such notifications is by changing the settings on the device itself.

25. VIDEO GAME BEHAVIOR DISORDER RESOURCES

Many people enjoy our games and services and use them in a safe and responsible manner; however, certain players do develop bad habits and problems with their gaming.

Here is our policy for responsible gaming:

• The player plays for pleasure or entertainment.
• The player exercises control over their play, and any associated spending.

If you’re not playing for entertainment, if you feel like you’ve lost control over your play or your spending, or if you are having trouble balancing the game with your other activities, then we encourage you to seek help. Here are some resources that may help you:

• SAMHSA National Helpline: 1-800-662-4357
• SMART Recovery Website: https://www.smartrecovery.org/

If you need a break from the game, we suggest requesting a block from your account.

26. HOW YOUR DATA IS UTILIZED

Here is how we use the data that you give to us:

• to provide our Services to you and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• to solicit feedback from your regarding our game and services
• to personalize the content you receive
• to provide you with your profile information
• to make your information available to other users in accordance with the privacy settings you chose
• to show you advertisements that are relevant to you

27. WHAT DATA DO WE COLLECT?

When you create an account with us, you may give us access to the following data:

• profile photo;
• username/nickname;
• player ID

Understand that you can choose whether to find other users of the game either through (a) your contacts or (b) Facebook contacts. If you chose to find other users through your phone contacts, we will access and collect your phone contacts, including the names, phone numbers, addresses and any other information that you have stored on your phone about your contacts. If you want to find other users through your Facebook contacts, we will collect your public Facebook information as well as names and profiles of your Facebook contacts.

Note that some gameplay may revolve around uploading your videos consisting of the game itself and image/video from your device’s front-facing camera. In doing so, you give us:

• your image and/or voice that you provide us by using your device’s front-facing camera. The use of your image means than we can store, copy, reproduce, distribute and make it available for other users
• your device location information
• metadata that is uploaded with such data.

28. CALIFORNIA PRIVACY NOTICE

This California Online Privacy Protection Act Notice is part of our overall Privacy Policy and specifically provides information on how we collect, use, disclose and otherwise process personal information of our players who are individual residents of the State of California within the scope of the California Consumer Privacy Act (CCPA).

A. PERSONAL INFORMATION:

According to the CCPA, personal information is defined as as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” and the use of Personal Information in this Section has this meaning.

Here are some of the categories of personal information we may collect:

We use the Personal Information collected above for the following business purposes:

1. Data analytics which leads to improving and optimizing our games and in turn, your experiences in our games

2. creating player accounts and allowing our players to play our games

3. identifying and suggesting connections with other players

4. communicating in-game updates and notifications, such as promotional offers

5. protecting the safety and security of our games, websites and company

6. making our games available to our players

7. protecting our rights and property in connection with our with our legal obligations

8. preventing fraud or potentially illegal activities, and to enforce our terms of use

9. managing and delivering customized advertising and marketing

10. player support requests

Pursuant to CCPA, Personal Information does not include publicly available information. For these purposes, “publicly available” means information that is lawfully made available from federal, state, or local government record.

Note that “Publicly available” does not entail biometric information collected by an entity about a consumer without that consumer’s knowledge. Information is not “publicly available” if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available. “Publicly available” does not include consumer information that is deidentified or aggregate consumer information.

B. Disclosure of Personal Information

We share your personal information among our entities as well as with certain third parties. We may allow the following categories of recipients to access Personal Information:

• entities within our corporate group
• payment processors
• analytics groups
• security providers
• advertising and marketing partners
• as necessary and required by law

Note that we do not sell nor have we sold the personal information of our users. We do not sell personal information of California players to third parties, regardless of the player’s age.

C. Your California Privacy Rights

Your Rights Pursuant to California’s Privacy Rights:

D. Your Right to Know

California residents have a right to request the disclosure of certain information from our data collection and use of your personal information. You may be entitled to:

• knowledge of business or commercial purpose for collecting that personal information.
• categories of personal information we collected about you.
• categories of third parties with whom we share that personal information
• specific pieces of personal information we collected about you

We can only provide you with this information if you request us to.

E. Your Right to Delete

You have the right to request that we delete your Personal Information that we have collected from you and that we have retained (subject to specific exceptions and as necessary to comply with legal requirements).

Once we receive and confirm your request, we will delete your Personal Information that we have collected and retained, unless an exception applies.

F. Your Other Rights

You have right to designate an agent to make a request under the CCPA on your behalf and the right not to be discriminated against if you exercise any of your rights with us under the CCPA.

In order to be authorized to act on your behalf, your agent will need to provide us with proof that they have written permission to represent you. The request will also need to be made through our Support team process.

G. Making a Request

To exercise your rights under the CCPA, we will need to get from you a specific request. There are two ways to send us such a request:

(1) The first way is to send us the request through the “Settings” tab in our game. Please reference “CCPA” in your request.
(2) The second way is to send an email to our Support team.

Please make sure that you include sufficient information in your request as to what you want from us.

We may need to verify your identity before processing any request. We reserve the right to decline a request to exercise rights under CCPA, especially if we are unable to verify your identity.

If you are using an authorized agent, the authorized agent will still need to submit a request as stated above.

H. California Civil Code Section 1798.83 & Do Not Track Signals

Note that pursuant to California Civil Code Section 1798.83, if engaged in sharing data with third parties for direct marketing requests, we are required, upon request from a user, to disclose to it’s the user the identity of any third parties to whom the business has disclosed personal information within the previous year, along with the type of personal data disclosed.

We are required to respond to such a request once per year.

A company subject to California Business and Professions Code Section 22581 is required to allow any California resident under age 18 who is a registered user of our site, services or applications to request and obtain removal of content or information they have publicly posted.

Understand that such a request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

29. Additional Important Information

We do not currently respond to Do Not Track signals.

We may update our Privacy Policy, including or excluding this Section, from time to time with or without notice. All changes shall be effective from the date of publication unless otherwise provided in any notification of the changes.

If you access our games or websites from a third-party application you should read that third-party application’s terms of use and their privacy policy.

30. CHANGES TO THE PRIVACY POLICY

We will update you regarding any changes to our Privacy Policy. If we decide to make material changes to our Privacy Policy, we will tell you and other players by placing a notice in-game or on our website, or by sending you a notice to your e-mail address before the change becomes effective. We will ask for your consent where required by law.