Privacy Policy – Airport Panic:Game & Watch

Last updated: August 24, 2023

Intro

Hello! Welcome to the Spud Gun Games Privacy Policy. This policy describes how Spud Gun Games and its other “Group Companies” (Codojo Ltd.) collectively described as “SpudGunGames”, “Codojo”, “we”, “us” or “our”) and its third-party marketing and advertising partners collect, use, process and share information about you. This Privacy Policy applies to all of our games, whether played on our website www.spudgungames.com, on mobile devices, PCs or on other platforms such as Facebook. It also applies to our Marketing and Advertising activities on all platforms and other services that we will provide to you from time to time. In this Privacy Policy we refer to our games, websites, marketing and advertising activities and other services collectively as our “Services”.

When you download, access and/or play our games, or interact with our websites or other Services, you acknowledge the collection and use of your information in accordance with this Privacy Policy, including Codojo’s and our advertising partners’ use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. Those sections also explain how you can give your consent by opting in, or withhold or withdraw your consent to the use of your data for targeted advertising purposes. If you have any concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services.

Playing Airport Panic

When you download, access and/or play our games or use our other Services, we collect information about you. Most of this data comes directly from you or your device, such as device information, country and region, and game play information(such as levels attempted, high score). We use this data to provide our games and Services to you, including for the purposes of optimisation, preventing fraud, customising in-game offers and verifying purchases. We will also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising purposes.

Most of the information that we collect about you comes directly from you when you play our games, or interact with our websites, advertising or other Services. Broadly, the information we collect about you relates to the type of device you are using, how you play our games (such as levels attempted and purchases made) and will include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our games or Services. We will also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.

In more detail, depending on which of our Services you interact with, we will collect and process the following types of information:

details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our website(s), what device you use to access our games and services;
information that you provide us with when you fill in forms, answer questions or complete surveys when using any of our Services, when you create an account with us, including email address or if you invite your friends to use our games and Services;
if you contact us, for instance through our customer service channels, or respond to messages and communications that we send to you, we will keep a record of that correspondence;
your interactions with us on our social media channels;
information we collect via cookies and other similar technologies, as explained further below;
information as further set out in this Privacy Policy, including Marketing, and Advertising;
information we collect about you from our other Group Companies or other third party companies who have obtained your consent or have another legal right to share such information with us (including publishing partners, platforms, advertising platforms and partners and data aggregators who have obtained your consent). This will include attributes about you and your interests, as well as other games and services you use, demographic and general location information.

We will collect device level identifiers and other information associated with those identifiers including:

the type of device(s) you are using to play our games or access our Services, identifiers such as IP address, device identifiers, ad identifiers, and the country or region that you are playing in; and
how you play our games and interact with our websites or other Services (such as which of our games you are playing, your progress through the games, session time and duration, number of attempts at each level and purchases made).

In some instances, when you make purchases on or through our website(s), we will collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by Codojo. Unless otherwise stated we do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful.

When you purchase items in our mobile apps through the App Store, on Facebook or on Google Play, we do not collect or store any payment information from you.

We, our suppliers and group companies, will use this information:

to enable us to provide our games and other Services to you, to ensure that any purchases you make are verified on our servers and activated in the games, and to provide you with player support if you need it;
to enable us to optimise our games for you and for the device that you are using, as well as to deliver customised in game events, offers and promotions; for the other purposes as set out in this Privacy Policy, including for Marketing and Advertising purposes; and
to enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our terms of service or where necessary to defend, exercise or establish our legal rights including our rights under our Terms of Service (spudgungames.com/airportpanic/terms-and-conditions/).

We will also share your information with third party publishers who develop and provide games and other Services to you on our behalf.

We analyse and use the information that we collect on an de-identified or aggregated basis for product development, to analyse the performance of our games, to troubleshoot and to improve and optimise the games to ensure the best player experience for our players as a whole.

A more detailed description of some of the ways that we use your information is set out below and in the other sections of this Privacy Policy, including our section containing disclosures for US residents.

Providing and optimising our Services

We use your information to enable us to provide our websites, advertising and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players.

Customer Services

We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We will also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.

Analytics and Research

We use analytics tools, which will include third party analytics tools, to collect information about how you play our games or use our Services. Those tools will use cookies or other similar tracking technologies. We will use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We will also create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content.

Social and Community

We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we will also republish your posts to those channels.

Promotions and Competitions

From time to time we will run promotions or competitions during which we will collect certain personal information from you, such as your name, address, post code, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition. We will also publish the names and entries of competition entrants. That information will also be combined with other account information and will be processed, stored and shared in accordance with this Privacy Policy.

Cheating, crime and fraud prevention

We will use personal data that we hold to prevent cheating, crime or fraud. We will also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police.

Legal uses

We will use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.

Visiting our websites

When you visit our other websites, such as spudgungames.com, and other websites and forums operated by us (“Websites”), we collect information about you, such as details about how you use and interact with such Websites. We will use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with our advertising purposes, and for research or analysis.

The information we collect and process about you when you visit our Websites includes:

information that you provide us with when you fill in forms or create posts on our Websites, or when you create an account with us;
details of your use of the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);
if you contact us or respond to messages and communications that we or other users of the Websites send to you, we will keep a record of that correspondence;
your interactions with us on our social media channels; and
information we collect via cookies (which are small text files placed on your device), and other similar technologies. Cookies allow us to collect data, such as your device’s model, operating system and screen size and other information about how you use our Services. For more information, see Ad identifiers, cookies and similar technologies below.

We, our suppliers and Group Companies, may use this information:

as necessary in order to provide the Websites and related services to you
for the purposes of contacting you, for example as part of customer service or to send you updates about the Websites;
for the purposes of managing your account and relationship with us and improving your experience when you use the Websites;
for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes;for the purposes of marketing and promotion of SpudGunGames’s products, for example sending you communications (including by email) for these purposes on our, or a third party’s behalf. For example, we might send you information about merchandise relating to our games. If you do not want us to use your data in this way please let us know by contacting us at privacy@spudgungames.com;
to create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with the Websites;
for the purposes of preventing cheating, crime or fraud. We will also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention; or
as otherwise expressly set out in this Privacy Policy or as required by law.

When using online forums such as SpudGunGames Community, please be aware that in addition to your user name, any questions, answers, comments or submissions that you post will be publicly available and any data you provide can be read and/or used by other users. You should therefore only share content that you are comfortable sharing publicly.

SpudGunGames Profile and Playing Socially

You can choose to add information to your SpudGunGames Profile or to connect our Services to your account with a third party network (such as Facebook). If you do this, then your personal information will be visible to other players and we’ll also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising

SpudGunGames Profile

When you play our games, we may give you a randomly generated unique identifier which we will associate with a SpudGunGames account known as a “SpudGunGames Profile”. Your SpudGunGames Profile will not be personally identifiable unless you choose to add your personal information to it, such as your name, avatar, email address or other information.

Your SpudGunGames Profile and the information it contains will be visible to other users of our Services. If you choose to add personal information to your SpudGunGames Profile, it will be visible to your friends and other players anywhere in the world.

If you choose to view another individual’s SpudGunGames Profile, that individual and other users of our Services will know that you have visited them because some of your social information and a link to your SpudGunGames Profile will be displayed on that individual’s SpudGunGames Profile.

Connecting with a third party network

Where we make this available, you can choose to log in to your SpudGunGames Profile using your account details with a third party network, such as Facebook, Google or Apple. If you do this, you will be able to use your account to log in on multiple devices and synchronise progress across those devices. Where available, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress), or access other functionality we make available in our games and other Services, such as inviting friends to play, asking other players for lives and 1-2-1 messaging.

Information we receive from Facebook

If you log in to your SpudGunGames Profile using your Facebook account details, we will receive some of your Facebook account information. If you choose to play our games online on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your SpudGunGames Profile. Exactly what information we receive will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information.

We will also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our games. You can choose not to allow us to access your email address in the Facebook dialog box the first time at which you associate your Facebook account with your SpudGunGames Profile. If you provide us with your email address we will from time to time use that email address to send you marketing emails about our other games and Services. You can opt out of this at any time – see Opting-out of direct marketing from SpudGunGames below.

Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see you and your progression in our games, you can prevent this by disconnecting from Facebook from within our games and updating your app permissions from within your Facebook settings.

We would recommend that you read Facebook’s Privacy Policy (https://www.facebook.com/full_data_use_policy) and review your privacy settings from time to time to make sure that you understand fully how your Facebook data is shared.

Information we receive from Google

If you log in to your SpudGunGames Profile using your Google account details, we will receive some of your Google account information. Exactly what information we receive will depend on your settings in your Google account, but typically we will receive your basic public profile information such as your name, email address and profile picture. If you choose to grant us access to your Contact List, we will use and store this to help you find those of your Google contacts that are already playing our games.

You can revoke future access to your information at any time by following the steps at https://support.google.com/accounts/answer/112802?hl=en.

We would recommend that you read Google’s Privacy Policy (https://www.google.com/policies/privacy/) and review your privacy settings from time to time to make sure that you understand fully how your Google data is shared.

Information we receive from Apple

If you log in to your SpudGunGames Profile using your Apple account details, we will receive some of your Apple account information. Exactly what information we receive will depend on your settings in your Apple account, but typically we will receive your basic public profile information such as your name and email address. You can revoke future access to your information at any time by following the steps at https://www.apple.com/uk/privacy/control/

We would recommend that you read Apple’s Privacy Policy (https://www.apple.com/legal/privacy/en-ww/) and review your privacy settings from time to time to make sure that you understand fully how your Apple data is shared.

Marketing

Where we record your preferences as permitting us to do so, (see further below on how to change your preferences) we and our third-party partners use information collected about you to send you marketing communications about other SpudGunGames games and related Services based on your interests. For example, we will serve ads within our Services or place ads on third party websites, apps and Internet-connected devices.

We will use the information that we hold about you to promote SpudGunGames own Services in a number of ways. This might include:

advertising within third party websites, apps and Internet-connect devices;
showing you promotions for other SpudGunGames or Codojo Limited games in the games you play; or
sending you marketing materials by email.

What information do we use for marketing?

We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we will have about you, such as:

ad identifiers and other non-personal information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
the games you play and information about how you interact with our games and Services;
your age, country or region, and gender; and
other information that we might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.

Marketing partners

When we market our games in media published by other companies, we use various third-party marketing partners to assist us on our behalf, and we will share information which we have collected about you with such third parties for these purposes.

Our marketing partners will help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for SpudGunGames games or Services, they will serve you with a SpudGunGames ad while you are using other websites and services.

By accepting this Privacy Policy and downloading or continuing to play our games, and unless you opt out of interest-based advertising as explained in this section, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies.

This Privacy Policy does not apply to the collection of your information by our marketing partners. We recommend that you review our partners’ privacy policies for more information. A list of our marketing partners and their privacy policies can be found here.

Opting-out of direct marketing from SpudGunGames

You can exercise choices over the direct marketing we send you in the following ways:

you can withhold your consent for us to send you direct marketing emails by opting out when we collect your email address or by electing not to share your email address with us when you first create an account using your Facebook details;
you can remove yourself from receiving email marketing from us at any time by simply clicking the unsubscribe link in any direct marketing email we send to you or sending an email to privacy@spudgungames.com; and
to disable interest-based advertising, please see How to adjust your preferences for interest based advertising below.

You should note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and you will see advertising for SpudGunGames products, but that advertising will not be targeted using your personal information.

Advertising

Our games will include advertising for third party products and services.

SpudGunGames and our advertising partners collect and use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games.

Airport Panic has an opt-in consent form to gather consent and permissions for our advertising and analytics based activity. You can change your preferences at any time in the setting pages of our games.

Ad identifiers, cookies and similar technologies

To provide our games, Websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.

We use information that we hold about you to better target ads for third party goods and services to people that might be most interested in them. These ads will be shown to you within our games or Services.

What information is used for advertising?

We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our games that might be of interest to you. This includes information such as:

ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
the games you play and information about how you interact with our games and Services; your age, country and region, and gender; and
other demographic and interests based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.

Advertising partners

When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.

Our advertising partners will combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.

If you consent to, or are opted into, the collection and use of your data for targeted advertising purposes by our advertising partners your data will be used as set out in this section and as further described in our partners’ privacy policies. We recommend that you review our advertising partners’ privacy policies for more information. A list of our advertising partners and their Privacy Policies can be found here. You can refuse or withdraw your consent to such use at any time – for more information, see How to adjust your preferences for interest based advertising.

How to adjust your preferences for interest-based advertising

You can choose to prevent your device’s ad identifier being used for interest-based advertising (referred as “personal ads”, “cross-contextual ads” or “targeted ads”) by updating the settings on your device

When we record that your preference is not to be shown interest-based advertising, you will still be able to play our games and you will still see advertising in our games, but those ads will not be targeted using information that we hold about you or which our advertising partners collect about you from our games. However, you will still receive ads based on contextual criteria such as the game that the ad is displayed in, or the region in which your device is located.

Players in the United States should review the US residents section to know more about sales and sharing of personal information and options available to residents of some states.

For players not in US states with rights to opt out of sales or sharing of personal information: If you would prefer that your personal information is not processed to receive interest-based ads, you can update your preferences via the settings menu in relevant games. Please note that outside of US states with applicable privacy laws, even if you have opted-out of interest-based ads in our games, you will still receive interest-based ads from Facebook. If you would prefer that Facebook does not use your personal data for interest-based ads, you need to log into your account on Facebook and update your settings there.

Opting out of interest-based advertising at a device level: You can choose to prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings. If you live in the USA, the EEA or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for EEA users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available)

Ad identifiers, cookies and similar technologies

Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to:

recognise you and your device;
provide interest-based advertising to you;
allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
allow us to understand how you interact with our websites (for example, where we use cookies such as the Google Analytics cookie on our Websites);
allow our payment processors to process your payment instructions; and
enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language.

For more information on the cookies we use and why we use them, please see here.

How do ad identifiers, cookies and similar technologies work?

Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser.

Your rights

You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below. Users located in the United States should review the US residents section below.

Those rights include:

Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we will not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why.
Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know at privacy@spudgungames.com and we will correct it as soon as we can.
Data deletion. You have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please contact us at support@spudgungames.com. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we will still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We will also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages will be cached on other players’ devices and we will not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.
Account deactivation. If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We will ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, such as Gold Bars or Boosters will be lost and we will not be able to restore them in the future.
Data portability. In some circumstances, you will have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
Restriction of processing. In some cases, you will have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us
Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below).
Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you will need to opt out of all of them individually. It will take a few days for us to update our records before any opt out is effective.
Right to opt-out (California, USA): California residents have the right to opt out of the sale of personal information, which is defined in a way that will include the transfer of data to third parties to personalize ads for you. If you opt out of the ‘sale’ of your information, we will not sell your information, including to our advertising partners, but you will still see ads in the game and some of our partners will deliver ads to you, based on information they hold on you. See How to adjust your preferences for interest-based advertising for more information.There are other ways in which you can control the personal information that we collect about you. For instance, you could disconnect your Facebook or other social network account from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone. Finally, you could limit or prevent the use of cookies in your web browsers. More information on all of these options is provided elsewhere in this Privacy Policy.

Children

You must be the age of 16 or over to play Airport Panic and use its Services. We do not knowingly collect or solicit personal information from or direct or target interest-based advertising to anyone under the ages of 16 or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us. Airport Panic is intended to be played by adults and we do not knowingly collect, and do not wish to collect, information about children. Please do not play our games or use our Services if you are under the relevant age.

General

Our Privacy Policy contains further details about:

who we share your information with and the reasons for sharing it;
measures we take to keep your information secure;
the legal bases under which we process your data;
how long we retain your information and where we store it;
when and why we share your information with third parties, including transfers outside of the European Economic Area (the “EEA”); and
changes or updates to our Privacy Policy.

Sharing

In addition to the other disclosures described in this Privacy Policy, we will also share your information:

where we have your consent to do so (including as set out in this Privacy Policy);
as reasonably necessary in order to provide the Services to you (for example, by providing your personal information to suppliers we will use to fulfil the Services or to communicate with you);
where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment processors);
where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
as we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of SpudGunGames, our users, or others; and
if there is a sale of the assets of SpudGunGames or corporate restructuring, or as a result of a change of control of SpudGunGames or one of its Group Companies, or in preparation of any of these events. Any third party to which SpudGunGames transfers or sells SpudGunGames’s assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

We will also share your information with our service providers if necessary to enable them to provide services to us.

Security

SpudGunGames takes appropriate security and technical measures to protect your information from unauthorised access, loss and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.

Legal Bases

In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal bases which we rely upon are the following:

Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested – and that we have agreed – to provide to you, such as our games, customer services, chat functionality and third party social network connectivity;
Legal Obligation. This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data;
Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics, research and optimisation of our games and other Services; and
Consent. This is used as a legal basis in the following contexts: (i) the collection of data stored on your device by us and our advertising partners, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and you can withdraw your consent to this by uninstalling our games; (ii) the storage of data on your device by us and our advertising partners, including through the use of cookies. By accessing and using our Services, you consent to this storage and you can withdraw your consent by updating your cookie settings; and (iii) the use of your data by us and our partners for targeted advertising purposes (for more information, see Marketing and Advertising above). You consent to this collection when you accept this Privacy Policy and you can withdraw your consent to this processing by following the steps at How to adjust your preferences for interest based advertising. Where we ask for your consent to use your data for any other purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent.

In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease playing our games and stop using our Services.

Retention

We will keep your information for as long as your account is active or we consider necessary for the purposes described in our Privacy Policy. We will also retain and use your information for as long as is required in order to comply with our legal obligations.

Location of storage

We store your information on servers that we control which are primarily based in the EEA. We will also use servers and engage providers that are located outside the EEA in order to process and store your information and to provide services to us.

International Transfer

We will transfer your information to affiliated entities or third parties to jurisdictions outside the EEA. Please note that these countries outside of the EEA will not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU model clauses) to allow the transfer of your information across borders outside of the EEA.

Changes to this Privacy Policy

We will update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us, unless we provide otherwise.

US residents

In addition to the information provided throughout this Privacy Policy, state privacy laws in the United States require that we disclose to consumers in those states additional information about the processing of their personal data. Below we describe the purposes for which we use and disclose personal data and, for each purpose, the categories of personal data we use and disclose and the categories of third parties to whom we disclose the personal data.

Service functionality: We use certain data to provide you with our Services and games, including to create and manage your account, enter a contract for sale or services, facilitate purchases or process payments, fulfill orders, send service communications, provide customer service functions, and conduct general business operations, such as accounting, recordkeeping, and audits, analyzing our performance, and meeting our legal obligations.
Service improvement: We use data you provide to improve, grow, and optimize our Services, including to maintain and verify the quality of our Services, develop new games, products, and other services, and understand how our Services are being used, our customer base and purchasing trends, and the effectiveness of our marketing.
Personalisation: We use data to offer you recommendations and tailor the Services to your preferences.The personal data we collect and use for these purposes includes:
- Personal data provided by you:
  - Contact information, including name, username, date of birth, email address, telephone number
  - Demographic information including your, date of birth, and country
  - Payment information, collected by our third-party payment processors to complete a purchase
  - Information that you provide when you register with a Service, including when you link a third-party account to your SpudGunGames Profile or play via a third-party account (such as your Facebook or Google account)
  - Information contained in your communications to us, including when you contact customer service
  - Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services)
  - Customer service information, such as any issues you raise and their resolution
  - Contact information, including name, username, date of birth, email address, telephone number
  - Demographic information including your, date of birth, and country
  - Payment information, collected by our third-party payment processors to complete a purchase
  - Information that you provide when you register with a Service, including when you link a third-party account to your SpudGunGames Profile or play via a third-party account (such as your Facebook or Google account)
  - Information contained in your communications to us, including when you contact customer service
  - Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services)
  - Customer service information, such as any issues you raise and their resolution
  - Contact information, including name, username, date of birth, email address, telephone number
  - Demographic information including your, date of birth, and country
  - Payment information, collected by our third-party payment processors to complete a purchase
  - Information that you provide when you register with a Service, including when you link a third-party account to your SpudGunGames Profile or play via a third-party account (such as your Facebook or Google account)
  - Information contained in your communications to us, including when you contact customer service
  - Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services)
  - Customer service information, such as any issues you raise and their resolution
  - Contact information, including name, username, date of birth, email address, telephone number
  - Demographic information including your, date of birth, and country
  - Payment information, collected by our third-party payment processors to complete a purchase
  - Information that you provide when you register with a Service, including when you link a third-party account to your SpudGunGames Profile or play via a third-party account (such as your Facebook or Google account)
  - Information contained in your communications to us, including when you contact customer service
  - Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services)
  - Customer service information, such as any issues you raise and their resolution
- Personal data automatically collected:
  - Websites visited before and after you use a Service
  - Browser type and language
  - IP address
  - Hardware and software information
  - Gameplay data
  - Communications
  - Usage data
  - Purchase history

We disclose this personal data to:

Various Group Companies which will use the personal information for their own marketing purposes
Service providers, including billing firms, customer service support, consultancies, information technology providers, cybersecurity providers, payment processors, accounting and auditing firms
Partners and licensees who provide you with goods or services you have requested, or create applications and websites that benefit our player community

SpudGunGames also publicly displays certain personal information about you, including third-party account information and gameplay information, on the Services, or the properties operated by our third-party partners and licensees. For example, your SpudGunGames Profile username will be displayed on leaderboards if you are a top player in a certain SpudGunGames game. If you have synced a third-party account with your SpudGunGames Profile, we, or our third-party partners or licensees, will make your username available to be searched by other users if you have not opted out of this feature

Sweepstakes, Promotions and Competitions: When SpudGunGames runs promotions or competitions, we collect certain personal data from participants to enter them into the promotion and to deliver any prizes won. We will also need to collect additional information in order for you to claim a prize. We will combine that data with other data we have collected about you and use such combined information for other purposes stated in this Privacy Policy. The personal data we collect and use for these purposes includes:
- Personal data provided by you
  - Contact information, including name, address, postal code, age and/or date of birth, email address, telephone number, and other information you submitInformation you provide in order to claim any prizes you win
We disclose this personal data to:
- Various Group Companies which will use the personal information for their own marketing purposes
- Service providers, vendors, or business partners, such as entities conducting promotions on our behalf. In some circumstances, such as disclosures to business partners for their own marketing purposes, we make these disclosures only with your consent.
Advertising and marketing: To send you marketing communications and newsletters, personalize the advertisements you see on our Services and third-party online properties, and measure the effectiveness of our advertising. The personal data we collect and use for these purposes includes:
- Personal data provided by you:
  - Contact information, including name, username, date of birth, email address, telephone number
  - Demographic information including your, date of birth, and country
  - Information that you provide when you register with a Service, including when you link a third-party account to your SpudGunGames Profile or play via a third-party account (such as your Facebook or Google account)
  - Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services)
  - Information about your interests in and use of various products, programs, and services
  - Marketing preferences
- Personal data automatically collected:
  - Websites visited before and after you use a Service
  - Browser type and language
  - IP address
  - Hardware and software information
  - Gameplay data
  - Communications
  - Usage data
  - Purchase history
  - Mobile advertising IDs, non-personal identifiers, and other information from your mobile device
We disclose this personal data to:
- Various Group Companies which will use the personal information for their own marketing purposes
- Online advertising partners, including partners who use Cookies to personalize, retarget, and measure the effectiveness of advertising, including on our mobile games
  - These partners will combine this personal information with information that they have collected about you when you use their services (or the websites and services of third parties) to serve you more relevant ads or to improve the accuracy of their targeting and measurement systems.
- Social media platforms
- Business partners, when you give us your consent to disclose your personal information to them
The personal data we collect and use for these purposes includes:
- Personal data provided by you:
  - Contact information, including name, username, date of birth, email address, telephone number
  - Information that you provide when you register with a Service, including when you link a third-party account to your SpudGunGames Profile or play via a third-party account (such as your Facebook or Google account.)
  - Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services.)
- Personal data automatically collected, including by monitoring and recording on your device:
  - Websites visited before and after you use a Service
  - Browser type and language
  - IP address
  - Hardware and software information
  - Gameplay data
  - Communications (including without limitation chat, text or voice communications)
  - Usage data
  - Activities on your device
- We will disclose this personal information to:
  - Various Group Companies which will use the personal information for the purposes listed above
  - Service providers such as platform providers, cybersecurity providers, tournament providers, and information technology providers
  - Other entities when we believe that this is necessary to protect the rights, property, or safety of any person
  - Regulatory or law enforcement agencies
Legal compliance: To comply with legal process, such as warrants, subpoenas, and court orders; to respond to lawful regulatory or law enforcement requests, such as when we have a good-faith belief that we must do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or will expose you or us to legal liability; to exercise, establish, or defend our legal rights; to protect the vital interests of any person; and to comply with applicable legal requirements. Such personal data includes:
- Any information requested through legal process or that we believe in good faith is necessary to respond to lawful regulatory or law enforcement requests for the purposes listed above.We will disclose this personal data to:
  - Regulatory or law enforcement agencies, including jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
  - Our legal advisors or consultants.
Corporate change: We will disclose any personal data that we have collected about you in connection with the sale of our business or assets in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event.

SpudGunGames is not responsible for the privacy practices of Codojo Group Companies and the use of your personal data by the Codojo Group Companies will be governed by those specific companies’ privacy policies, which you will find on each company’s website.

Your US Privacy Rights

Residents of some states have certain rights in relation to their personal data. We describe below the rights that will be available to you, depending on your state of residence.

Right to Request Access to Your Personal Data

You will have the right to request, up to two times in a 12-month period, access to the personal data we have collected about you and information regarding the source of that personal data, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. Please note that certain data will be exempt from such requests under law.

Right to Request Correction of Your Personal Data

You will have the right to request that in certain circumstances we correct personal data that we have collected about you. Some data will be exempt from such requests under law.

Right to Request Deletion of Your Personal Data

You will also have the right to request that we delete personal data that we have collected from or about you. Some personal data will be exempt from such requests under law. For example, we need certain types of personal data so that we can provide our Properties to you. If you ask us to delete it, you will no longer be able to access or use our Properties.

Limit Use of Your Sensitive Personal Data

California residents have the right to limit our use of their sensitive personal data if we use such personal data to infer characteristics about them. To exercise this right, please contact us at support@spudgungames.com;. Your right to limit our use of such personal data is subject to exception. In some states, we will be required to obtain your consent before collecting your sensitive personal data.

Sale and Sharing of Personal Data; Targeted Advertising; Profiling

Under the laws of some states, consumers have the right to opt out of the sale of personal data or the sharing of their personal data with third parties for targeted advertising (also known as cross-context behavioral advertising or interest-based advertising).

We share certain information with third parties who do work on our behalf for the business purposes we describe above.

We also will allow third-party advertising companies to collect information about your activity on our websites and in our apps, for example through cookies, mobile ad identifiers, pixels, web beacons and social network plugins. These advertising entities use information they collect to help us provide more relevant advertisements and for other purposes described in our Privacy Policy. You can control the sharing of your personal data for targeted advertising through our websites and apps in the following ways:

You can set up cookie controls through many browser settings and you can use industry-wide opt outs to control the use of cookies for interest-based advertising purposes.
You also can opt-out through the in-app Privacy and Security section, in the SpudGunGames mobile applications, once you opt out, we record your preferences. We will not share your data for these purposes.

The personal data collected through these methods is associated with your browser or device, so if you would like to opt out for this data you will need to disable cookies or trackers as described above. Because your opt-out preference is stored in a cookie, if you reset your advertising ID or clear your cookies then we will not recognize your device or your choices, so you must opt out again. You will also disable non-advertising cookies through your browser or device settings.

SpudGunGames recognizes Do Not Track settings.

Personal Data Collected Through SpudGunGames Profiles: In addition to the opt-outs related to advertising above, we support state privacy laws by allowing residents to opt out of any other future sale or sharing of their personal data for targeted advertising by using the Airport Panic’s privacy settings in the app. You can also submit a request to opt out of sales by emailing us at privacy@spudgungames.com.

How to Exercise Your Access, Correction, and Deletion Rights

You will exercise any privacy rights to which you are entitled by sending an email to privacy@spudgungames.com. To exercise your right to correction, please update your account information directly or send an email to privacy@spudgungames.com.

For security purposes, we will verify your identity – and will request information from you to do so – when you request to exercise your privacy rights. If you have an online account you use to interact with SpudGunGames, logging into your account will serve to verify your identity and request. We will request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, then we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

Some states permit you to designate an agent to make requests to exercise your rights as described above. We will take steps to both verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.

Once we have verified your identity (and your authorized agent, as applicable), we will respond to your request as appropriate. If we are unable to complete your requests, we will provide you information about the reasons that we could not comply with your request.

Profiling

We do not engage in “profiling” in furtherance of decisions that produce legal or similarly significant effects.

Right to Nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights, unless allowed under applicable law.

Appeals

Some state laws allow residents who are not satisfied with our response to their requests to appeal our decision by contacting us as described in the written notice we will provide to you.

Additional Privacy Information for California Residents

Depending on how you interact with us, SpudGunGames will collect the following categories of personal data about you. For information about the purposes for which we use and disclose data, and additional potential disclosures of personal data, please see US residents section above.

Identifiers, collected from you, our social media pages, or third-party subscription service providers, will be disclosed to our service providers and will be sold to or shared with business partners.
Financial information, collected from you, will be disclosed to our service providers. We do not sell or share financial information.
Protected classifications and other sensitive data, collected from you, will be disclosed to our service providers. We do not sell or share protected classifications and other sensitive data.
Commercial information, collected from you, will be shared with our service providers. We do not sell or share commercial information.
Geolocation information, collected from you and our analytics and advertising partners, will be shared with our service providers. We will sell or share coarse location information to our advertising partners; we do not sell or share precise geolocation information.
Internet or electronic network activity information, collected from you and our analytics and advertising partners, will be shared with our service providers and will be sold to our advertising partners.
Audio, electronic, visual, thermal, olfactory, or similar information, collected from you, will be shared with our service providers. We do not sell or share such information.
Inferences drawn about you, collected from you and our advertising and analytics partners, will be shared with our service providers. We will sell or share such information with our advertising partners.
Content of communications, collected from you, will be shared with our service providers. We do not sell or share content of communications.
Information of contacts that you supply to us will be shared with our service providers. We do not sell or share such information.

We determine the retention period for each of the categories of personal data listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such data, (3) internal operational needs, and (4) any need for the data based on any actual or anticipated investigation or litigation.

California residents have the right to opt out of the sale or sharing of their personal data, as explained as stated above.

We will collect your personal data in order to offer you the benefits and rewards you request. For example, we need your email address in order to verify your account to deliver an in-game item. If we do offer you the chance to participate in such a program, your participation is optional. If you choose to participate, your participation will be subject to the applicable terms or conditions, and you can withdraw at any time. Your information has no real currency value or its equivalent.

California Shine the Light Law

Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. We do not share our customer’s personal data with third parties for their own direct marketing purposes, without their approval. For inquiries regarding our disclosure policy, please send us an email to privacy@spudgungames.com.

California Privacy Rights for Minor Users

Since January 1, 2015, California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or remove data provided by you or publicly posted by you, by accessing your SpudGunGames Profile or another product or service as applicable and editing/removing your Information. You will need your password to access your personal account. You will also send us an email asking us to remove certain posted content at privacy@spudgungames.com. We will be happy to review, update or remove information and/or content as appropriate. Residual copies of data and/or content that have been removed from your account and/or the Services will remain in our backup systems for approximately one month. We will still retain your data to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your personal data will be blocked from use for any other purpose.

Additional Privacy Information for Nevada Residents

Under Nevada law, Nevada residents who have purchased goods or services from us will opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and service of interest to you and in the other ways described above. We do not believe that our sharing in this regard would qualify as a sale under Nevada law. Nonetheless, if you are a Nevada resident who has purchased goods or services from us, you will submit a request to record your preference to opt out by emailing us at privacy@spudgungames.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request.

Contact us

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several way of contacting us:

via email to support@spudgungames.com or
in writing to Codojo Ltd, 11/2 John Street, Edinburgh, Scotland, EH15 2EB.

For information collected under this Privacy Policy, the data controller is Codojo Limited.