Last Updated: Nov 12th 2021

GGPuzzle.Lab develops and publishes puzzle games for the mobile devices. This Privacy Notice (this “Notice”) describes the ways GGPuzzle.Lab (“Studio,” “us”, “our” or “we”) collects, stores, uses, discloses or otherwise processes personal information of our users (“users” or “you”) in connection with their use of our products or services.

This Privacy Notice covers the following topics:

● Sharing of your information

● Security of your information

● Personal information we collect and how we collect it

● Third-party websites and services

● How we use your information

● Online advertising

● Data retention

● Children’s privacy

● Transfer of personal information outside your country

● Managing your information

1. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

When you interact with or use our Services, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services (e.g., information about how you interact with our Services) and sometimes we collect the personal information directly from you when you use our Services (e.g., information you give us when setting up your account or user profile). At times, we may collect personal information about you from other sources and third parties, including other players.

A. Information We Collect Automatically or From You Directly

Registration Information

We may offer you the option to complete a user profile that is visible to other Studio users (“Account”). If you create an Account, you may provide us your name, a username, e-mail address, a password and other information that helps us confirm that it is you accessing your Account. We may do this through in-game dialog boxes, which you may choose to skip. If you sign into the Services with Facebook Connect, we will collect information that is visible via your Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook friends. Your Account may be used to publicly identify you as part of social features of the Services, which may include user-to-user interaction, chat or messaging functionality, public leaderboards, head-to-head competition, and other similar features. Your username associated with your Account will be public and will be shown to other users. In addition, your username will allow others to access information on your user profile that is considered public or that you have designated as public in your user profile settings.

Technical and Usage Information

When you access our Services, we may use cookies and other similar technologies to collect (i) certain technical information about your mobile device or computer system, including IP Address, mobile device ID (IDFA, Google Advertising ID or other identifiers), and the version of your operating system; and (ii) usage statistics about your interactions with the Services, including the links, objects, products and benefits you view, click or otherwise interact with (also known as “Clickstream Data”). Our emails may also contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. In connection with your use of certain Services, we will create and assign to your device an identifier that is similar to an account number. In addition, in certain circumstances, we may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, character name, or e-mail address. We may also infer your approximate geographic location based on your IP address.

Payment Information

When you order any good or service through the Services, including any virtual currency or virtual good, we collect certain non-financial transaction information related to these purchases, including what you purchased, the price, and the date. Your in-app purchase transactions are processed by third-party payment processors, such as Apple (for purchases on iOS devices), Google (for purchases on Android devices), or Amazon (for purchases on Kindle devices). The third-party payment processors will collect your name, phone number, e-mail address, mailing address, billing address, and complete credit card information to enable them to process your payment. The third-party payment processors may also retain this information to enable you to purchase additional items through our Services without having to re-enter your payment information each time. Please note third-party payment processors do not share your financial information, like credit card numbers, with us. In addition, please note that the third-party payment processors’ processing of transactions and collection and use of your personal information is governed by their terms of service and privacy policy, and purchases through these third parties may also be subject to additional policies. We encourage you to review the terms of service and privacy policies of those third parties to learn more about how they handle your personal information.

Information Collected by or Provided to Customer Support

When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game-play or activity on the Services, and your username or ID number. We will also store the correspondence and information within the correspondence that you choose to share with us.

Communication Preferences

We may collect information about your interests and communication preferences that you choose to provide, such as when subscribing to news or alerts.

Surveys, User Research Projects, Competitions and Promotional Events

If you choose to participate in, or fill out any forms relating to, Studio surveys, user research projects, competitions (contests/sweepstakes), promotional events, or similar activities, we will collect your contact information (such as your name, email, and phone number, address and postal code) to enable you to participate in the activity and to allow us to communicate with you, as well as any other information that we request that you provide for purposes of the activities, including audio or video recordings, photos, and/or screen captures. In connection with Studio surveys and user research projects, we may also collect your age, gender, opinions, responses to certain research questions, prompts, or surveys, and other personal information, consistent with the purposes of the Studio survey or user research project.

On occasion, we may also collect your shipping and billing information to send you certain rewards or incentives, such as if you are a participant in a Studio survey or user research project, a competition winner, or if you purchase our products or services. In addition, if you are a part of our event or promotion partner, we may also collect your personal information including your name, company email, and company address.

Please note that your participation in any Studio surveys, user research projects, competitions (contests/sweepstakes), promotional events, or similar activities, is completely voluntary.

B. Information We Collect From Other Sources

We may collect or receive information from the following other sources (i) other Service users who choose to upload their email contacts; (ii) third party information providers, such as digital advertising companies; and (iii) social networking sites. We may combine this information with the information we collect from an individual directly.

C. Sensitive or Special Categories of Information

We typically do not request or seek to elicit sensitive or special categories of information, but you may choose to provide this information to us in connection with certain of the interactions described above, including when you ask for assistance from our Customer Support team. The meaning of sensitive or special categories of information varies by jurisdiction and it could include, for example, health, genetic or biometric data, or precise location information.

2. HOW WE USE YOUR INFORMATION

We use information collected through our Service for purposes described in this Notice or disclosed to you in connection with our Service. For example, we may use your information for:

Service Delivery

− Create your Service accounts and allow access to our Services;

− Identify and suggest connections with other Studio users;

− Operate our Services;

− Improve our Services;

− Understand you and your preferences to enhance your experience and enjoyment using our Services;

− Respond to your comments and questions and provide customer service;

− Provide and deliver products and services you request;

− Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;

− Conduct and administer surveys, user research projects, competitions and promotional events that you participate in;

− Prevent fraud or potentially illegal activities, and enforce our Terms of Use;

− Enable you to communicate with other users; and

− Fulfill any other purpose for which you provide personal information.

Marketing and Advertising

− Deliver and target advertising and marketing and promotional information to you; and

− Communicate with you (including via email and push notifications) about promotions, contests, rewards, upcoming events, and other news about products and services offered by us and our selected partners.

Research and Development

− Create aggregate or anonymous information derived from the personal information we handle, which we may use and disclose for research, development and other lawful business purposes;

− Link or combine personal information with other information we get from third parties to help understand your preferences and provide you better services; and

− Analyze information to choose to provide to us in connection with Studio surveys and user research projects to gain insights into how users engage with our Services, to improve our Services, to consider developing new products or services, and other lawful purposes.

Compliance and Protection

− Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

− Protect our, your or others’ rights, privacy, safety or property (including by investigating, bringing, making or defending legal claims);

− Audit our internal processes for compliance with legal and contractual requirements or our internal policies;

− Enforce the terms and conditions that govern the Services; and

− Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Push Notifications

We may occasionally send you push notifications through our Service to send you game updates, high scores and other service-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

3. SHARING OF YOUR INFORMATION

We may share information we collect for the following purposes:

− Service Providers. With service providers that perform services on our behalf or enhance our Services, including hosting services, customer service, analytics services and to assist us in our marketing efforts;

− Payment Processors. With third-party payment processors that process payments you make;

− Advertising Partners. Advertisers, ad exchanges and other ad technology companies that require the data to select and serve our relevant advertisements to you and others, and assist us in our marketing efforts, including as described in the Online Advertising section below;

− Affiliates. With our parent company, subsidiaries and other affiliates;

− Professional Advisors. With professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us;

− Authorities and others. With law enforcement and public authorities, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above;

− Business Transferees. With acquirers and other relevant participants (and their advisors) in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Studio or our affiliates (including, in connection with a bankruptcy or similar proceedings); and

− Your specified recipients. We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction.

4. ONLINE ADVERTISING

Interest-Based Advertising

To the extent we display advertising in our Services, with your consent as may be required by applicable law, we may share or we may allow online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time to enable them to play or display ads on our Services, on other devices you may use, and on other websites, apps, or services. Typically, though not always, the information we share is provided through cookies, software integrations, or similar tracking technologies, which recognize the device you are using. We and our third-party partners use this information to try to make the advertisements you see online more relevant and tailored to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Such information includes the following:

- Device make, model and operating system;

- Device properties related to screen size & orientation, audio volume and battery;

- Carrier;

- Operating system;

- Name and properties of mobile application through which the user interacts with the Services;

- Country, time zone and locale settings (country and preferred language);

- Network connection type and speed;

- IP Address;

- Gender;

- Keywords;

- City- and/or country-level geolocation data;

- Internet browser user-agent used to access the Services; and

- Advertising ID (IDFA on iOS devices and GAID on Android devices).

We utilize certain forms of display advertising and other advanced features through Google Analytics, including, but not limited to, Remarketing with Google Analytics, the DoubleClick Campaign Manager Integration, Google Ads, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service and to tailor our advertisements and content to you. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. To learn how you can opt-out of data collection by Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

Opting-Out of Interest-Based Advertising

You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of interest-based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice. AppChoices is available at the links below:

You may also limit data collection by third parties by visiting your mobile device settings and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”) or by exercising other privacy options in your device’s settings.

Please note that electing to opt-out will not stop advertising from appearing in your browser or applications or reduce the number of ads that you receive. You will still receive ads, but those ads may be less relevant to your interests. In addition, if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to apply your opt-out choices to that particular browser or device.

Please note that the opt-out tools described in this section are provided by third parties, not by us. We do not control and are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

5. SECURITY OF YOUR INFORMATION

We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage.

However, no security system is impenetrable, and we cannot guarantee the security of your personal information. Any transmission is at your own risk.

6. DATA RETENTION

We store data on servers in the U.S. or any other country in which the Studio or its affiliates, subsidiaries, agents or contractors or service providers maintain facilities. We retain your personal information for as long as needed to provide you Services, unless we are required by law to delete or if we accept your request to delete the information pursuant to applicable law. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

When we no longer require your personal information, we will look to delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will apply security measures to your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

7. CHILDREN’S PRIVACY

The Services are not intended for use by children (aged 16 or such higher age as required by applicable law). We do not knowingly collect personal information from children through the Services or knowingly allow them to use our Services. If we learn that we have unintentionally collected personal information from a child, we will delete that information. If you believe that we might have collected personal information from or about a child, please contact us at support+privacy@athena.studio

8. THIRD-PARTY WEBSITES AND SERVICES

The Services may contain integrations or links to third-party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party. Please note that the Studio is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy policies and online terms of those third parties to learn more about how they handle your personal information.

9. TRANSFER OF PERSONAL INFORMATION OUTSIDE YOUR COUNTRY

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Economic Area, United Kingdom or Switzerland, your personal information may be processed outside of those regions, including in the United States.

10. MANAGING YOUR INFORMATION

Subject to certain exemptions, you can manage information we receive about you.

If you would like us to delete your information, you may send an e-mail to support+privacy@athena.studio and place “Delete My Account” in the subject line. If you proceed with the deletion of your account, you will no longer have access to the game account or services associated with your account. Other steps you should take should you wish to delete your account include disassociating your Facebook account from our mobile games, if applicable, and deleting the game from your mobile device. Please note that if you ask us to delete your account, all your progress in the game and any unused virtual items will be lost and we may not be able to restore them in the future. Please note that your information, for example records pertaining to payments or customer service matters, may be retained for legal and accounting purposes. If you have sent or posted content on the Service, we may not be able to delete it.

If you wish to review, change or correct the information we have about you, you may send an e-mail to support+privacy@athena.studio making this request.

For all of the above requests, we will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems.

11. SPECIFIC PROVISIONS FOR EEA, UK AND SWISS INDIVIDUALS

Your Rights With Respect to Your Personal Information

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold

- Erasing or Restricting Access to Your Information. You may request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.

- Transferring Your Personal Data (Otherwise Known as Your Right to Data Portability). You have the right to receive your personal data that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.

- Right to Object to Processing. You have the right to object to our processing of your personal data, under certain conditions.

- Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your personal data based on that consent. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.

If you wish to exercise any of your rights detailed above, please contact us at support+privacy@athena.studio or write to us at the address set forth in the “Contact Us” section. If you make a request, we will typically look to respond within one month, although a longer period may be permitted.

● Where we need to do so to perform a contract we are about to enter into with you or have entered into with you – for example, this will be relevant where we use your personal information to provide you with the Services, to operate the Services and to create and maintain your Account.

● Where we need to comply with a legal or regulatory obligation – for example, this will be relevant where we are legally obliged to provide your personal information to authorities to comply with lawful governmental or regulatory requests.

• Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the relevant authorities (e.g., by the European Commission, UK Government and/or Swiss Federal Council).

• Transfers to territories without an adequacy decision.

o We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for personal information by those relevant authorities (e.g., the United States).

o However, in these cases, we may look to use specific appropriate safeguards approved by the relevant authorities, which are designed to give personal information the same protection it has in the EEA, UK or Switzerland – for example, standard-form contracts approved by relevant authorities for this purpose.

If you want further information on the specific mechanism(s) used by us when transferring your personal information, please contact us at support+privacy@athena.studio. Visit the “Contact Us” section below for contact information.

12. SPECIFIC PROVISIONS FOR CALIFORNIA CONSUMERS

These additional provisions for California consumers apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide additional rights to know, access, correct, delete, and opt out, and requires “businesses” collecting or disclosing personal information to provide notice and a means to exercise those rights.

Your California Privacy Rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

o The categories of Personal Information that we have collected.

o The categories of sources from which we collected Personal Information.

o The business or commercial purpose for collecting and/or selling Personal Information.

o The categories of third parties to whom we disclose Personal Information.

o The categories of Personal Information that we sold or disclosed for a business purpose.

o The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

• Correct. You can request that we correct any information on your account that is not accurate, complete, or updated by providing us with the necessary information to correct it.

• Deletion. You can ask us to delete the Personal Information that we have collected from you.

• Opt-out of sales. You can opt-out of any sale of your Personal Information.

• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Right to Opt Out of Information Sales

We do not “sell” information about our users as most people would commonly understand that term. However, consistent with common practice among companies that operate online, we do “share” information in the sense that we allow certain third-party advertising networks and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use your personal information for purposes of analyzing and optimizing our Service and advertisements on our websites, on other websites or mobile apps, or on other devices you may use, to personalize content or to serve ads that may be more relevant to your interests, and to perform other advertising-related services such as reporting, attribution, analytics and market research. To learn more about how third parties collect information automatically on our Site and the choices you may have in relation to those activities, please see our Online Advertising section, above.

How to Exercise Your Rights

To exercise your right to know, right to access, right to correct, right to delete, right to opt out of information sales, or any other right you may have under applicable law, please submit a request by emailing support+privacy@athena.studio or by writing to us at the physical address in the “Contacts” section below, with the subject line “California Rights Request” and specifying which right(s) you would like to exercise (for example, your right to delete). We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

We aim to respond to a consumer request within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

Personal Information That We Collect, Use and Disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. See Sections 1-3 of our Privacy Policy for additional details. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. We do not intentionally collect or seek to elicit “sensitive personal information” under the CPRA.