Privacy Policy

Last Update: January 10, 2024

‍This Privacy Policy (“Privacy Policy”) describes how and when we collect, process, use, secure, and share information collected in connection with our games, websites, content, products, and any related services(collectively, the “Services”), and your choices and rights in relation to the Services. For purposes of this Privacy Policy, “Ares” (or “we” or “us”) refers to Ares Interactive, Inc. and its parents, subsidiaries, representatives, affiliates, officers, and directors for websites and applications that link to this Privacy Policy or otherwise make it available toyou.We want you to feel confident when using our Services. In this Privacy Policy we want to give you an overview as to how we process your personal data and on what statutory bases as well as your associated data protection rights. Please read this Privacy Policy carefully. We may update it from time to time by posting a new version on our website, aresinteractive.com. If we make any material changes, we will notify you through the Services.

Information We May Collect and How We Collect It

‍The types of information we collect depends on how you use our Services. We may collect various types of information, including information you provide or make available to us directly, information collected from your devices, and information collected from other sources, like social networking sites and gaming partners.  Some of this information may be considered “personal information” or “personal data” under applicable privacy or data protection laws. Generally, we collect the following information:

  - Identifiers / Contact Information: Name, user name, email address, phone number, unique IDs,       mobile device ID, platform ID, gaming service ID, advertising ID (IDFA, Android ID) and IP address
   - Protected Characteristics: Age and gender
   - Commercial Information: Purchase and     usage history and preferences, including gameplay       information
   - Internet / Electronic Activity: Web / app     browsing and gameplay information related to the       Services; information     about your online interaction(s) with the Services or our advertising;       and details about the games and platforms you use and other information related to installed       applications
   - Device and Usage Data: Device type, software and hardware details, language settings,       browser type and version, operating system, and information about how users use and interact       with the Services (e.g., content viewed, pages visited, clicks, scrolls)
   - Profile Inferences: Inferences made from your information and web activity to help create a       personalized profile so we can identify goods and services that may be of interest
   - Sensitive Information: Precise location     information (if you allow the Services to collect your       location), account credentials (user name and password), and contents of communications via       chat features and functionality. When you visit one of our websites, we process technical       information, such as your IP address, browser type and location, specific browser settings,       interactions with the interface of the site, operating system to properly display the sites and       make their functions available. To collect and store this type of data, we may use cookies.       Cookies are small files that are automatically placed on your device and make available certain       technical data to us.  We only use technologies setting cookies on your device that are strictly       necessary for the use of the websites and their functionalities.

How We Use Information We Collect and Our Legal Bases

‍We use the information we collect for various business and commercial purposes, as follows:

‍Business Purposes

‍We use information we collect for our business purposes, including to:
   - Provide the Services;
  - Fulfill product orders and other requests, respond to your questions, and communicate with       you;
   - Enhance and personalize your experience on the Services, including to recognize you, maintain       your preferences and  settings, connect you with other users and link to your third-party           platform, gaming, and social networking accounts;
   - Provide technical and other support;
   - Review the use and operations of the Services, develop new products or services, and conduct       analyses to enhance or improve our software, content, marketing, support, and Services;
   - Conduct internal marketing and demographic studies;
   - Address issues with the Services or other business needs;
   - To protect the security or integrity of the Services, users and our business such as by       protecting against and preventing violation of our terms and policies, including combating       fraud, piracy, cheating, tampering, unauthorized transactions, claims, and other liabilities, and       managing risk exposure;
   - Interact on your behalf with the third-party platform, gaming, and social networking accounts       you connect with our Services; Participate in other processing that we inform you about when       you provide your information or when you consent to such processing; and
   - As permitted by law

‍Commercial Purposes

‍We use information we collect for commercial purposes, including to:
   - Provide you and other users with customized content, targeted offers, and advertising on the       Services, via email and text message, or on other sites, mobile applications, or social media on       behalf of us or our business partners;
   - Contact you with information and promotional materials;
   - Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events       sponsored or managed by us or our business partners; and
   - Analyze our users, in combination with other data, to assess our user base and target marketing       at other similar groups.

‍Legal Reasons to Process Personal Data

‍If you are based in a location that requires us to establish legal grounds, we process your information on the following grounds:
   - Establish and perform our contract with you (such as the Terms of Use applicable to our       Services, or to take steps at your request, such as to complete transactions with you and to       allow you to play our games online);
   - Compliance with a legal obligation;
   - For our or our partners' legitimate interests, such as to improve our Services; perform analytics       to better understand our users; conduct direct marketing (when we do not need your consent);
      otherwise supporting our business, operations, and Services; and enforce and prevent       violations of our Terms of Use;
   - Protect your vital interests or those of another person (for example, another player); and
   - With your consent, such as when you sign up for direct marketing or you connect your game       account with a third-party service.

‍Sources of Information

‍How we obtain information depends on how you use the Services. For example, we collect information:

   - you provide directly to us, such as when you set up an account, sign-up for marketing, or       contact us;
   - about the games you play (automatically)
   - from third-party platforms, such as when you play our games or access our Services with third-      party accounts
   - automatically, including through cookies and similar tracking technologies from third parties,       such as advertising networks, business partners, third party information providers, and other       players

--- Gameplay Information

‍When you use the Services, we automatically receive information about your gameplay. Gameplay information includes your platform ID or gaming service ID, game achievements, game scores and performance, IP address, MAC address or other device IDs, other platform / device information, and other information and statistics regarding your use of the Services. We collect gameplay information even if you do not register for the Services. We may combine gameplay information with other information we have about you. We also may use internal and third-party anti-cheat technologies to detect and prevent cheating within our Services.

‍---Platform, Gaming, and Social Networking Information

‍We collect information when you access our Services with third-party platform accounts, such as a gaming platform account, gaming network service account, or social networking service account. When you access our Services in this way, the third-party platforms provide us with information about you.  For example, depending on your use of, or activity on the third-party platform, we receive your user name, your friends list, or account information necessary to provide the Services or a purchased in-game item. The third-party platform may allow you to control what information is provided to us. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.

‍---Information from Third Parties

We receive information from third parties to update the information that we collect about you. We may receive information from public databases, platform manufacturers, analytics providers, game developers, and other business partners involved in providing the Services to you, that includes demographic information and information about your interests. We may collect publicly available information, including from social media, to protect our users, employees, facilities, and Services, and to aid investigations. We also receive information from other individuals who use our Services. This may include information about you if you are mentioned in comments on the Services or an individual sends us a direct message.

‍How We Disclose Information

‍We are in the business of creating great games, not selling information. Subject to your legal rights, we may disclose the information we collect about you, and may enable you to share this information, with a variety of third parties in various ways, including:

   - With our affiliates, who provide data processing services necessary to provide you with our       goods and services (for example, to support the delivery of, provide functionality on, or help to       enhance the security of our Services across the world) or who otherwise process personal       data for purposes described in this Privacy Policy;
   - With vendors, consultants, development partners, business partners, payment processors, and       other third-party service providers as necessary to carry out work on our behalf and otherwise       provide the Services.  We may also share some of your information only with your consent or at       your direction;
   - With other players, to enable you to interact with them and to share gameplay-related       information such as high scores and other leaderboard information;
   - With the general public, if you choose to share information when contributing content to our       Services through a forum, blogs, social features, or the like;
   - Where you choose to take advantage of social sharing features or related tools that let you       share games and other actions you take on our Services, with the public, social media       platforms, and/or your social media friends or contacts;
   - With others who share your device, if you make your account available to them through that       device;
   - With specific third parties if we believe disclosure is required by applicable law, regulation, or       legal process;
   - With law enforcement officials, government authorities, or other third parties if we believe your       actions are inconsistent with our terms or other policies, and/or are fraudulent or in violation of       applicable law, or as we determine necessary to protect the rights, property, or safety of Ares       or others;
   - In connection with an actual or proposed merger, consolidation, restructuring, sale of company       stock and/or assets or other corporate change, including during the course of any due       diligence process; and/or
   - In an aggregated or pseudonymous form or otherwise in a form that cannot reasonably be       used to identify you.

‍--- Personalized Ads

‍We work with certain advertising partners to show you personalized ads. In order to show you advertisements that are relevant to you, we collect and share with these advertising partners certain usage, game and purchase information, including identifiers, based on your consent. For the display of personalized advertising in our Services, we rely on the so-called Transparency and Consent Framework (TCF) from the IAB. With your consent, we create an individual profile about you and / or target groups into which we classify you (so-called segments) in order to display personalized advertising in the Services. In connection with the display of this advertising, processing is also carried out with your consent to measure the advertising (in particular to determine the performance and success of an advertisement), for target group research (in particular to learn more about the target groups to which the advertising is displayed), for the development of services and for the technical security and optimization of these advertising displays. You may disable cross-platform tracking in the settings of your device.

‍Data Retention

‍The specific personal information we process and our reasons for doing so often vary depending on how you use the Services. Therefore, the length of time that we retain personal information can also vary. We generally retain personal information for as long as we reasonably need it for the purposes described in this Privacy Policy (such as complying with our legal obligations, where we have an ongoing legitimate business need to do so, managing internal records, enforcing our contracts and terms, fraud prevention, resolving disputes, and for safety reasons), unless a longer retention period is required or permitted by law.

The primary factors we consider in determining retention periods can include minimum requirements under applicable law, relevant industry standards, the types of data in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (such as defending ourselves against legal claims), and whether the personal information is required to prevent fraud or similar abuse of the Services (including to enforce prohibitions against cheating and other unauthorized behavior and to prevent banned players from using the Services).

We store your game and account data for as long as your account exists. After that, we anonymize it within 60 days.  Please note that your game account is not automatically deleted when you uninstall the game from your device. If you want your game account to be deleted, please contact us. Support inquiries which you send us by email are deleted within 180 days after we resolved the issue you contacted us for.

‍Children’s Privacy

‍Generally, we direct our Services to a general audience and we do not knowingly collect personal information from children under 13 years old (or older, if applicable law provides for different protections). We may direct certain Services to an audience of all ages---including children. For these Services, we may restrict the collection of personal information on the Services from anyone, apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services from children, or get a parent's permission to collect personal information from children. If we become aware that a child has provided personal information without a parent's permission, we will promptly delete this information. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.

‍Data Rights

‍Depending on your location, you may have certain rights over your personal information, including the right to:
   - Request access to or a copy of your personal information;
   - Request deletion of your personal information; Request correction or modification of your       personal information;
   - Be informed about the personal information we collect and/or process about you, the sources       of personal information, and the third parties with whom information was shared or sold and for       what purposes;
   - Withdraw consent, if processing is based on consent;
   - Opt-out of the sale or sharing of your personal information (including targeted advertising);
   - Opt-in/out of financial incentives; and
   - Limit the use and disclosure of your sensitive personal information

You can make a data rights request in relation to your personal information by sending an email to privacy@aresinteractive.com. We will respond to data requests within a month. We may take steps to verify your identity before we can respond to your request. To the extent these rights apply to you, they may be limited in some situations -- for example when we are under a legal requirement or have a compelling interest for processing your personal information, or when the personal information is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a privacy authority. A list of privacy authorities is available here. You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you've authorized them to act on your behalf, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent's identity.

‍Contact Us

If you have questions or concerns about this Privacy Policy and our use of your personal information, you can contact us by email at privacy@aresinteractive.com, orby postal mail at: Ares Interactive, Inc., Attn: Legal Department, 2809 CarltonRd, Austin, TX 78703. If we receive a formal written complaint from you, we will attempt to contact you directly to resolve your concerns.

‍Changes to Privacy Policy

‍We reserve the right to make changes to this Privacy Policy. Please check back from time to time to review these changes. If we change this Privacy Policy in a material way, we will provide appropriate notice to you and, as appropriate, provide additional choices regarding such change. As permitted by applicable law, your continued use of the Services means that you accept these changes.