Player Privacy Notice

Effective January 28th, 2018

Firecraft Studios Limited Corp. (referred to as “Firecraft”, “We”, “Our”, or “Us”) goal is to create games that people (“Player(s)”) enjoy, delivering fun in an otherwise busy world! To deliver that fun, we need to collect some personal data, but let’s be clear, our primary goal is to deliver fun, not broker your personal data to the world. Privacy seems to be getting more regulated by the day, which requires us to put in certain language. We’ll do what we can to make it as short and understandable as possible.

This Player Privacy Notice (“Notice”) applies when Players use our (“Services”) which means the games available to download and our advertising software. The Notice describes how we collect, use, store, and share personal data (“Data”), along with the choices Players have. If a Player resides in the European Union, it also describes additional privacy rights and choices.

If Players don’t want us to use Data in the ways described in this Notice, they may not play the games or use the Services. That’s really not our goal, so we hope Players find this Privacy Notice acceptable.

Data We Collect

Data Players give us directly

- Username (which can be anonymous)

- Communications sent to us or customer support

Data Players instruct us to connect (optional)

- Social profile name and identifier, profile picture, friends list, and email address

- Gender, age, user language, country and time zone

Data the Services or device create when Players play

- Game interaction such as the Player level, how long it takes to complete a level

- Approximate or ‘coarse’ physical location, country

- Device identifier, Player identifier, IP address, type of device and operating system, browser language, app performance, time spent and clicks, game state and time and date of activity

- Ads served, ad interaction during the game, and Data from our other apps and Services on the device

Payment Data (optional)

- In-app-purchase data is managed by the third-party platform Players select and those third-parties do not share financial Data with us but may share non-financial data about an in-app-purchase

How We Use Data and Our Legal Basis for Processing It

We use Data to provide the Services. There are a lot of specific uses that go into running a gaming Service and those are explained further below. As a reminder, we’re not in the business of brokering personal Data.

We use Data under several legal bases including: to provide the Services (perform our contract also known as our Terms of Service); run the business operations enabling the Services (our legitimate business interests so long as those interests are not overridden by a Player, and legal compliance); to protect Players, Player’s rights, or vital interests of someone else (like another Player), and otherwise with consent.

We use Data to:

- improve and optimize the Services and Player experience;

- create accounts and enable game play;

- store game progression such as levels Players attain, and coins collected;

- identify and suggest connections with other Players and personalize the Services;

- communicate to Players, including in-game updates, new Services, and hopefully interesting promotions;

- enable Players to communicate with each other;

- provide technical support and respond to Player inquiries;

- protect the safety and well-being of Players;

- protect our rights, property, and business;

- prevent fraud or potentially illegal activities, and to enforce our Terms of Service ;

- manage and deliver targeted, contextual, and behavioral advertising;

- administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;

- comply with legal obligations, resolve any Player or third-party disputes, and enforce our agreements with Players and third parties; and/or

- conduct research.

When We Share Data

Instructed by Player’s

- If Players connect and share game updates or chat with social-media friends. Players should carefully consider what they post and share publicly. We do not control social-media and are not able to remove information that you share.

Enable advertising (so we can make money to run our business)

- Advertisers and ad networks serve relevant ads to Players and we may share advertisement performance data, device interaction data like device ID, unique ID’s from the game, and contextual game performance data.

Operate our Service (with confidentiality, data processing, and service agreements in place)

- We share Data with companies and internal corporate affiliates who provide services such as technology hosting, payment processing, analytics, marketing, and advertising optimization, to enable our Services and games.

Comply with legal requests, protect Players, and enforce our terms

- With a good faith belief, we may access, monitor, and share Data with third parties: to satisfy laws and regulations, to respond to lawful requests; to report suspicious or potentially criminal behavior, personal or economic threats against us or Players; to prevent potential cyber-attacks or information security vulnerabilities; to address an emergency that poses a threat to the health or safety of a person; and/or to protect us and enforce our Terms of Service.

Corporate transaction (with confidentiality and service agreements)

- We may share Data in the event we undergo or evaluate a corporate business transaction like a merger, acquisition, or a sale of all or part of our assets (like selling a game).

Your Rights and Choices

Specific rights for EU Players may be obtained by contacting us (information provided below).

Withdrawing consent .

If we collected Data based on consent, you can withdraw your consent at any time. It will not affect the processing of Data based on other lawful processing such as legitimate interests.

Access to, copy of, and deletion of Data

Players may request access to their Data. Players will need to validate their identity prior to receiving access. If the Data is inaccurate or out-of-date, Players can update the Data. Players can request a copy of their Data. Players can also request Data be deleted. Some Data may be retained for legitimate processing for certain periods of time, which will be disclosed at that time.

General rights for all Players

Third Party Sharing (turning it on or off)

The device used to access the Services has settings that enable Players to control what Data is shared. While each device is different, these settings are typically under the setting’s icon and may also be available within the Services settings menu of the game.

When Players share Data from social sites or third-party apps, they must follow the instructions for changing the sharing settings from that social or third-party app.

Promotional Communication from Us (Turning it on or off)

Players may receive device push notifications from us, that can be turned on or off by going to the device settings. Players may also be able to turn them on or off by going to the game settings. Email settings are available in the app settings menu, if we send email communications.

Third Party Advertising (Turning it on or off)

The Services may contain ads that are served by third-party ad networks and service providers. Players can turn on and off targeted ads in a number of ways, however the game will still have ads but they may be less relevant. Players can control this on the device by resetting the advertising identifier or IDFA depending on which mobile operating system it has. Players can also go to:

- Your Online Choices website for the EU

- Digital Advertising Association for iOS , Android , Amazon

Children’s Data

The Services are not targeted nor available to Players under the age of 16 (“Children”). Children are not permitted to use the Services and we do not knowingly collect any Data from Children.

If we learn that we have inadvertently gathered Data from Children, we will take reasonable measures to promptly remove such Data from our records.

International Operations and Transfers of Data out of EU Countries

IMPORTANT: To play our games and use the Services, Data is sent to the United States and other countries outside of the E.U.

Data is stored on equipment located in the United States and may be stored on equipment in other countries. Data from the E.U. may be transferred to, and stored at, a destination outside of the E.U. The Data may be processed by employees and affiliated entities, or one of our business partners or service providers outside of the E.U. Such processing will be consistent with the section above, “We use Data to”. When Data is transferred outside of the E.U. we take reasonable steps to ensure that Data is treated securely, lawfully, and consistent with this Notice. While the laws of the country a Player resides may be different than countries where we transfer Data to, we take considerable steps to ensure Data is subject to suitable and legally compliant safeguards and/or transferred to countries that have been deemed adequate.

If Players have a question, concern, or data protection inquiry, the fastest way to receive an answer is to contact customer support. The next most expeditious way to receive an answer is to email us at dataprotection@firecraftstudios.com . We will attempt to answer questions in a timely and satisfactory manner. If Players do not receive a timely acknowledgement of the compliant or if we have not addressed a compliant satisfactorily, Players should please contact their local data protection authority.

Lastly, Players may contact us by mail at:

Firecraft Studios Limited Corp.

Attn: Data Protection Officer

C/O Maples Corporate Services Limited

PO Box 309

Ugland House, Grand Cayman

KY1-1104, Cayman Islands

dataprotection@firecraftstudios.com

Retention of Data

We keep Data while Players use our Services to ensure the games work properly. Once a Player terminates an account, most of that Data is not retained. Some Data like payments are kept for regulatory purposes. We also keep Data as necessary to enforce our Terms of Service and legal rights. Otherwise, we do not retain Data beyond what is necessary to provide the Services and maintain our business operations.

Security of Data

In a world where it seems there is a security breach in the news on a daily basis, we know the security of Data is important. In addition to limiting what Data we collect and how long we keep it (above), we have a lot of people across the company focused on protecting the Data we store. We use reasonable and appropriate security measures and technology, keep it updated regularly, and scale it based on the amount and sensitivity of the Data.

Players can help by choosing a unique and complex password when using the Services and remaining on guard for suspicious emails and other activities. If a password is guessed or a social network used to sign-in with is compromised, access using that password to our Services will be successful and appear to be valid, as our Services will have been provided the correct password.

When we use third parties to process Data, we require the same if not more stringent security protocols as our own.

While we take precautions against possible security breaches of our Services and Data no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. However, we will notify Players if their Data is compromised and let them know our recommended actions.

Contact Us

The fastest way to get an answer to a question is to go to our help and support page. If that doesn’t work, Players can email us at dataprotection@firecraftstudios.com . Lastly, we do respond to physical mail addressed to Firecraft Studios Limited Corp., C/O Maples Corporate Services Limited, PO Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands, however it is by far these least quick method. If it is urgent, please go to the help and support page first to contact us.

Changes

We may revise or add specific instructions, policies and terms to this Notice. When those changes are material, we will notify Players by updating the policy on the website and app. By continuing to use the Services, Players agree to the revised Notice.