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PRIVACY POLICY

Version: 3.1

Date of Last Update: 9 December 2022

This GKL Media Privacy Notice (the “Privacy Notice” or “Notice”) is provided to help you understand our practices regarding how we collect, use, share, and protect personal data. In this Privacy Notice, “GKL Media” refers to GKL Media Holding Corp. and its subsidiaries. We may also refer to GKL Media as "we" or "us". This Privacy Notice applies whenever you visit our websites, play the games that link to this Notice, or otherwise access any of our other products and/or services, mobile applications, or any other applicable platforms and/or devices (the “Service”). This Privacy Notice does not apply to games offered specifically by the following GKL Media subsidiaries: Wooga GmbH, Seriously Digital Ltd, Supertreat GmbH, Reworks Oy, and JustPlay.LOL Ltd; the privacy notices for those games are available via the respective applications and websites.

By using the Service, you agree to the collection, disclosure, storage and use of personal data as described in this Privacy Notice. If you do not want GKL Media to collect, store, use or share the personal data you provide in the ways described in this Privacy Notice, you should not play GKL Media’s games or use our Service.

  1. Personal Data We Collect

    GKL Media collects personal data to fulfil one or more of its functions and activities, as described in this Privacy Notice.

    When you use our Service (including through a social network), you may give us information directly in a number of ways, including:

    1. to set up your account;
    2. in response to surveys or other research we conduct;
    3. to participate in contests and sweepstakes;
    4. via social media;
    5. by participating in group communications or chats;
    6. in communications with customer support agents and account managers;
    7. at conferences, conventions, and other events.

  2. Personal Data That We Get from Others

    We may collect or receive information about you from other sources like third-party applications, such as an app store, third party login service, and social networks on which you play our games. We may use this information along with information you provide us directly in a number of ways as described in this Privacy Notice, for example, to help you and your friends connect or to serve you advertising tailored to your interests.

    If you play GKL Media’s games or access our Service on connected third-party applications or connect our Service to any third-party applications, including social networks like Facebook, GKL Media may receive certain information about you from the provider of the third-party application. The information we receive depends on the GKL Media game you’re playing, the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.

    For example, GKL Media may collect and store some or all of the following information shared by the third-party application:

    1. your first and last name;
    2. your profile picture or its URL;
    3. your user ID number (like your Facebook ID number), which may be linked to other information like your name and profile photo, and your friends’ identifiers;
    4. your friends list, which includes the user ID number and other information of your friends, like their names and profile photos;
    5. the login e-mail you provided to the third-party application;
    6. your physical location and that of the devices you use to access our Service;
    7. your gender;
    8. your birthday and/or age;
    9. information about your activities on or through the third-party application;
    10. other information you have shared on the third-party application;
    11. any other information that you or the provider of the third-party application share with GKL Media.

    If you access our Service from a third-party application or connect our Service to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Notice.

    If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

  3. Cookies and Automated Information Collection

    GKL Media, our service providers, and third parties may place cookies on your device when you access or browse the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes. Information contained in a cookie may be linked to personal data. We may use cookies for purposes such as improving the quality of GKL Media’s Service, making the Service easier to use, tailoring recommendations to interests and serving targeted ads. Third party advertisers may also use, place, or read cookies or other technologies as described below on your device, and those practices are subject to their own policies.

    For more information on how you can opt-out of or disable cookies, please see the Your Rights section below.

    Other Technologies

    We, our service providers, and third parties may also employ other technologies including (i) web beacons, which may allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which may allow us or our advertising partners to advertise more efficiently and effectively by recognizing your device(s) on, off, and across different services and devices and identifying the source of a new installation; and (iii) local shared objects, also known as flash cookies, which may help us to reduce fraud, remember your in-game preferences, and speed up load times.

    We, our service providers, and third parties may use cookies and other technologies described to collect information about your device, browser, and/or activities, such as:

    • the type of device you are using;
    • your device’s operating system and version;
    • your mobile device’s identifiers, like your MAC Address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
    • your browser type;
    • your browser and/or device language;
    • referring and exit pages and URLs;
    • platform type;
    • the number of clicks on a page or feature;
    • domain names;
    • landing pages;
    • pages viewed and the order of those pages;
    • the amount of time spent on particular pages;
    • in-game activity, including the date and time of activity.

  4. How We Use Personal Data

    GKL Media may use personal data for a variety of business purposes as described in this Privacy Notice, including to fulfill our contractual obligations, complete transactions you request, comply with law, and for other legitimate business purposes, such as to:

    • create game accounts and allow gameplay;
    • operate, improve, and optimize our Service and our players’ experiences, including by measuring interest in and engagement with our Service;
    • personalize our Service, including to identify and suggest connections with other GKL Media players, and convert connections from your social media into in-game connections;
    • enable players to communicate with each other;
    • provide technical support and respond to player inquiries;
    • authenticate and/or verify individual identities;
    • protect the safety and well-being of our players;
    • protect GKL Media's rights and property in connection with our Service;
    • address technical issues and maintain and/or enhance network and information security;
    • conduct audits, ensure internal quality control, and take safety precautions;
    • prevent, investigate, and/or prosecute fraud or potentially illegal activities and enforce our Terms of Service;
    • manage and deliver contextual and behavioral advertising;
    • notify players of in-game updates, new products, content or promotional offers;
    • administer and deliver rewards, surveys, sweepstakes, contests, gifts, and/or other promotional activities or events sponsored or managed by us or our business partners;
    • comply with our legal obligations, resolve any disputes we may have with you or other players, collect any money owed us, and enforce our agreements;
    • conduct research, including by using personal data to create de-identified and/or aggregated data. De-identified and aggregated data are not personal data and we may use and share such data for any legally permissible purposes.

    Your interactions with our Service may be tracked across platforms and/or devices.

    In addition to the above, if you have provided your e-mail address to GKL Media, we may use it to communicate with you in a number of ways, including to respond to customer support inquiries; keep you and others informed of your gameplay, comments from friends, and in-game status and promotions; and tell you about gift and neighbor requests. Some messages, like invitations for friends to join you in a game, may include your name and profile photo. We may also send promotional messages ("Promotional Communications") directly or in partnership with other parties. For more information on how you can opt-out of Promotional Communications, please see the Your Rights section below.

    We may use technologies that (a) may be considered automated decision-making or profiling, and/or (b) include artificial intelligence to evaluate personal data that we collect (including, for example, in-game activity and communications within our Service) to improve our Service (for example, to prioritize customer support inquiries to shorten response times, personalize the game experience, and to understand trends in response to certain features in our Service) and for other legitimate business purposes. We will not use these technologies in a way that has a legally significant impact on you, unless we have your consent, or we are otherwise legally permitted to do so.

    We may use personal data for any other purposes communicated to you at the point of collection, or otherwise with your consent.