TRUSTe

Scopely Privacy Policy

Effective Date: January 1, 2020

Contents

  • About this Privacy Policy

This Scopely Privacy Policy (“Privacy Policy”) describes how and when we may collect, use, secure, and share information collected in connection with our games, mobile apps, websites, content, products, and any related services (collectively the “Services”), and your choices regarding that information. For purposes of this Privacy Policy, “Scopely” (or “we” or “us”) refers to Scopely, Inc. and its parents, subsidiaries, representatives, affiliates, officers, and directors.

Please read this Privacy Policy carefully. We may update it from time to time by posting a new version on scopely.com with an updated date. If we make material changes, we will notify you, prior to the changes becoming effective, through the Services or by other means if you’ve provided us additional contact information (e.g., using the email address associated with your Account, as defined in our Terms of Service). Your continued use of the Services after the Effective Date will be an acknowledgement of our updated practices.

  • Information We May Collect and How We Collect It

We may collect various types of information, including information you provide or make available to us directly, information collected from your devices (including web and mobile), and information collected from other sources, like social networking sites and gaming partners. Some of this information may be considered “personal information” or “personal data” under applicable privacy or data protection laws.

Information You Provide

You may provide information directly to Scopely when you:

  • Use or access the Services, including when you create a Scopely Account (as defined in our Terms) or make in-app purchases;
  • Connect with or access our Services using a third-party ID or log-in, such as an ID for a social networking site or gaming service;
  • Communicate with or contact others using our Services, including when you use chat, “invite a friend,” “email this page,” or other similar features;
  • Contact us, including for customer or technical support;
  • Participate in Scopely offers, contests, or special events;
  • Subscribe to newsletters or sign up to hear about current or upcoming products); and/or
  • Complete surveys offered by us or on our behalf.

Depending on how you choose to use the Services, you may provide us with the following information:

  • Things like your first and last name, username or handle, third party service ID, email address, phone number, home address or shipping address, and other contact information.
  • Your photo, avatar or other image.
  • Your date of birth, and gender.
  • Purchase or payment information.
  • Other information such as chat records, friends’ names and contact information, and non-precise location information you choose to share (for example, when you connect with our Services through social features).

Information Collected or Generated When You Use our Services

When you access or use our Services, we collect information from and about you and the device(s) you use. This may include the following information:

  • IP address,unique device identifiers, advertising identifiers, device serial numbers, and similar identifiers.
  • Hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, or clickstream data.
  • Approximate location inferred from IP address.
  • In-game purchase information.
  • Game scores and achievements, and other information as reasonably required to offer and enhance our Services.

Information Collected Using Cookies and Similar Technologies

We and our affiliates and partners may use cookies, beacons, software development kits, mobile analytics software, and/or similar technologies for a number of purposes, including to authenticate users, prevent fraud, remember preferences and settings, analyze advertising and messaging campaigns, analyze traffic and trends, personalize content (including ads), and otherwise provide the Services. These technologies may collect information about your use of our Services, pages you view, links you tap, messages you open, and other actions taken in connection with our Services.

Depending on the choices and settings available for the browser(s) you use, you may be able to disable cookies in your browser settings, but this could affect the availability and functionality of our Services. For information on interest-based advertising and how to opt out, see the Interest-Based Advertising section below.

Information Shared With Us Through Social Features

Some of our Services may incorporate features offered by social networks and other third-party sites, and in some cases, you may access our Services using single sign-in services like Facebook Connect. If you choose to take advantage of these features, we may collect additional information you choose to share with us, including the following:

  • Your name, user ID, social username, and contact information.
  • Your gender, age, date of birth, and language preference.
  • Your profile picture and the profile pictures of your friends or contacts.
  • Other information such as time zone, the organizations and links on your profile page, the names of your friends or contacts, and other information you share in connection with your profile.

If you allow contact information to be shared with us, we may use that information to communicate with you or with your invited friends as described in this Privacy Policy and as further described at the time you choose to share that information (for example, we may suggest friends to play with, or may help you invite a friend to play with you).

Information Collected From Other Sources

We may also collect information about you from other sources, including from our third-party partners or service providers, publicly available sources, feedback from other players, or social networking sites as described below. We may combine this information with other information in our possession, which helps us to update, enhance, and analyze our Services, and provide tailored experiences for you.

  • How We Use Information

We may use the information we collect for a number of business and commercial purposes, including to:

  • Perform internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing, and research;
  • Understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns), as well as offer discounts or personalized pricing;
  • Maintain the safety, security, and integrity of our Services, for example by authenticating users and providing account security and fraud detection;
  • Send you news and/or marketing communications (by email, phone, or text), including information about Scopely or third-party offerings we think may be of interest to you;
  • Administer contests, surveys and sweepstakes you enter, and notify contest winners and award prizes;
  • Fulfill a purchase or send you order confirmations or other requested product or Service information;
  • Facilitate your communication with friends and other users, and enable features that allow you to share information with other people (for example, if you choose to use friend invite features); and/or
  • Comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Services.

  • How We Share Information

We may share the information we collect about you, and may enable you to share this information, with a variety of third parties in various ways, including:

  • With vendors, consultants, business partners, payment processors, and other third-party service providers as necessary to carry out work on our behalf and otherwise provide the Services;
  • With other players, to enable you to interact with them and to share gameplay-related data such as high scores and other leaderboard information;
  • With the general public, if you choose to share information when contributing content to our Services through a forum, blogs, social features, or the like;
  • With the public or with social media friends or contacts, where you choose to take advantage of social sharing features or related tools that let you share games and other actions you take on our Services;
  • With others who share your device, if you make your Account available to them through that device;
  • With specific third parties if we believe disclosure is required by applicable law, regulation, or legal process;
  • With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our terms or other policies, and/or are fraudulent or in violation of applicable law, or as we determine necessary to protect the rights, property, or safety of Scopely or others;
  • In connection with a merger, consolidation, restructuring, sale of company stock and/or assets or other corporate change, including during the course of any due diligence process; and/or
  • In an aggregated form or otherwise in a form that cannot reasonably be used to identify you.

In some cases, we may enable you to access third-party products or services through our Services. Please note that those products or services are offered by people or companies not affiliated with or controlled by us, and we are not responsible for their actions, their terms, their use of information, or their products or services. If you submit your information to a third party, that third party’s treatment of your information is governed by their privacy policy, which may differ from this Privacy Policy and which we encourage you to review. For example, forums.scopely.com is hosted by a third party, Discourse, whose privacy policy is available at forums.scopely.com/privacy.

  • Interest-Based Advertising

We work with third-party advertising partners like Facebook as well as Google, MoPub, and their partners (listed here and here). We may share certain of your information with these partners to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences.

If you prefer to opt out of having your web viewing behavior used for interest-based advertising, you can learn how to do so by clicking here, or if located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, by clicking here. If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may do so through your device settings (“Limit Ad Tracking” on iOS and “Opt Out of Ads Personalization” on Android). Please note that you may continue to receive generic ads that are not based on your preferences.

  • Your Rights and Choices

You can access and modify any personal and other information that is made available to you in your Account or in-app. You can manage your information as described below, and you may have additional rights related to that information as described elsewhere in this Privacy Policy.

Accessing, Updating, or Correcting Your Data

You are expected to maintain accurate, complete, and up-to-date information in connection with your Account, but we provide you functionality to update or correct that information directly in-app. You can also access a range of information in-app, including things like your user name, picture or avatar, social log-in, game performance and progress, Virtual Items, chats, or other information you may have entered in-app.

Deleting Your Data

We offer you the ability to request deletion of personal information we have collected and stored about you, subject to our Data Retention policy described below. If you would like to have your personal information deleted with respect to any games you’ve played, please open an in-game help ticket via the Help section for that game. If you have played multiple Scopely games and want to have your personal information deleted as to all of them, please open a help ticket directly in-game via the Help section for each of those games, or contact privacy@scopely.com for help. Please also note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and if you share devices with someone else who uses the Services, that person may lose game progress or related account information and access. If you decide to use or access the Services again, Scopely may consider this a new Account and may collect personal information associated with that Account in accordance with this Privacy Policy.

Communication Preferences

Email, phone, and text: We may contact you at the email address(es) or phone number(s) provided in connection with your Account. You may opt out of these messages by following the unsubscribe instructions in the message (e.g. by tapping an unsubscribe link or replying “STOP”) or by contacting us at unsubscribe@scopely.com.

Push: In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.

Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Other Rights

In some cases, particularly if you are a resident of the EEA, the United Kingdom, or Switzerland, or if you are a resident of the State of California, you may have additional rights with respect to your personal data or personal information as defined under applicable laws. For more information on these rights, please refer to the additional disclosures below.

  • Data Retention

We may retain personal information where required by law or where we have an ongoing legitimate business need to do so. For example, we may retain such information to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, enforcement of our contracts and terms, or for safety reasons (e.g., we may retain certain information about an Account to prevent that user from opening a new Account).

  • Security

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and only those at Scopely with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.

  • Use by Minors

We do not knowingly collect or process personal data from or about, or direct or target interest-based advertising to, anyone under the age of 13 (or under the age of 16 for those in the EEA, United Kingdom, or Switzerland), nor do we knowingly allow such individuals to use our Services. If you believe we might have any data from or about a child under this age, please contact us. If we learn that we have inadvertently gathered such information, we will delete it.

  • Additional Information for Residents of the EEA, United Kingdom, and Switzerland

Rights and Choices Available to EEA Residents

If you are a resident of a member country of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you may have the following rights with respect to any information about you that constitutes “personal data” under EEA law:

  • Access your personal data: You may have the right to obtain confirmation regarding whether we process your personal data and obtain a copy of the personal data we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)
  • Rectify or correct your personal data: You may have the right to correct your personal data where it contains inaccuracies.
  • Request erasure (deletion) of your personal data: You may have the right to request that Scopely delete your personal data in certain cases, for example when it is no longer necessary to fulfill the purposes for which Scopely collected it. This right may be limited to the extent that Scopely is permitted or required by applicable law to retain the data. (Note that if you request deletion of your personal data, you may no longer be able to use or access the Services. If you share devices with someone else who uses the Services, that person may also lose game progress or related account information and access. If you decide to use or access the Services again, Scopely may consider this a new Account and may collect personal data associated with that Account in accordance with this Privacy Policy.)
  • Restrict or object to the processing of your personal data: In certain cases, you may have the right to object to Scopely’s processing of your personal data, or request that Scopely restrict that processing. Because the data that Scopely collects is generally required to provide the Services to you, if you object to the processing of your personal data, this may have the same effect as requesting deletion of this data. This right may be limited to the extent that Scopely is permitted or required by applicable law to continue processing the data. (Note that if you object to the processing of your personal data, you and others who use your devices to access the Services may no longer be able to use or access the Services.)
  • Request a portable copy of your personal data: In certain limited cases, you may be able to request that Scopely provide you with a copy of your personal data in a structured, commonly used and machine-readable format so that you can transmit it elsewhere.

If you wish to exercise any of these rights, please follow the instructions below:

  1. 1. Open the Scopely game(s) for which you wish to exercise your rights, and open an in-game help ticket via the Help section for that game. (If you have played multiple Scopely games and want to exercise rights as to all of them, please open a help ticket directly in-game via the Help section for each of those games.)
  2. 2. Once you have opened a help ticket, please clearly state which right(s) you wish to exercise for that game. For example, you can say “I want to delete my personal data,” or “please provide me with access to my personal data.” We cannot begin processing your request until you have clearly stated which right(s) you wish to exercise.
  3. 3. Make sure to include your city and country of residence in your request. We cannot begin processing your request until you have confirmed your residence. We will only use this information in order to fulfill and document your request.
  4. 4. Repeat the above steps for any other games for which you would like to make a request.

If you have trouble with any of the steps described above, you can contact privacy@scopely.com for help. We may contact you to confirm your choices and to ask for additional information as needed to verify your identity and process your request.

In addition to the rights described above, if we have collected and process certain types of personal data with your consent, you may withdraw that consent in the manner described when you provided consent. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to then, nor will it affect any processing based on lawful grounds other than consent.

In some cases, you may have the right to file a complaint with a data protection authority about our collection and use of your personal data. For more information, contact your local data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.

Legal Basis for Processing Personal Data

If you are from the EEA, the United Kingdom, or Switzerland, our legal basis for collecting and using your personal data will depend on the type of information and the context in which we collect it. In general, we collect personal data from you only where we have your consent to do so, where we need it to perform a contract with you, or where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need it to protect your vital interests or those of another person. If you have questions about the legal basis on which we collect and use your personal data, please contact us.

EU-US and Swiss-US Privacy Shield Principles

We comply with the EU-US and Swiss-US Privacy Shield Principles regarding the collection, use, sharing, onward transfer, and retention of personal data received from the European Union (EU), the United Kingdom, and Switzerland, as described in our EU-US and Swiss-US Privacy Shield certifications. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]. Privacy Shield participants are subject to the regulatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal data from the EU or Switzerland to third parties outside the EU and Switzerland.

If you have a Privacy Shield-related complaint, please contact us. If you feel your complaint remains unresolved after doing so, you may contact our US-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions more fully described at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke the Privacy Shield arbitration process when other dispute resolution procedures have been exhausted. In certain situations, Scopely may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  • Additional Information for Residents of California

Information We Collect, Use, and Disclose

California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in the “Information We Collect and How We Collect It,” “How We Use Information,” and “How We Share Information” sections of this Privacy Policy.

Generally, we collect the following categories of personal information, as defined by applicable California law:

  • Identifiers and contact information, including first and last name, username or handle, third party service ID, IP address,unique device identifier, advertising identifier, device serial number, email address, phone number, home address or shipping address, and your friends’ names and contact information;
  • Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream data;
  • Commercial information, including in-game purchase information;
  • Demographic information, including your gender, age, date of birth, and language;
  • Non-precise geolocation information, such as approximate location as inferred from IP address;
  • Visual information, such as your profile picture and the profile pictures of your friends or contacts; and
  • Other information you may share if you use social features when accessing our Services, including the organizations, links, and other information included on your social profile pages.

In the past 12 months, we have disclosed (or have enabled you to disclose) each of these categories of personal information to third parties when you have directed us to do so, or for other business or commercial purposes.

Scopely does not engage in “sales” of player personal information as defined by applicable California law.

Rights and Choices Available to California Residents

If you are a California resident, you may have the following rights with respect to any information about you that constitutes “personal information” under California law:

  • Access your personal information: You may have the right to obtain a copy of the specific pieces of personal information we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)
  • Request deletion of your personal information: You may have the right to request that Scopely delete your personal information. This right may be limited to the extent that Scopely is permitted or required by applicable law to retain information. (Note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and that if you share devices with someone else who uses the Services, that person may lose game progress or related account information and access. If you decide to use or access the Services again, Scopely may consider this a new Account and may collect personal information associated with that Account in accordance with this Privacy Policy.)
  • Obtain additional details regarding Scopely’s information practices: You may have the right to request disclosures regarding Scopely’s information practices. (Note that this information is generally available in this Privacy Policy.)

If you wish to exercise any of these rights, please follow the instructions below:

  1. 1. Open the Scopely game(s) for which you wish to exercise your rights, and open an in-game help ticket via the Help section for that game. (If you have played multiple Scopely games and want to exercise rights as to all of them, please open a help ticket directly in-game via the Help section for each of those games.)
  2. 2. Once you have opened a help ticket, please clearly state which right(s) you wish to exercise for that game. For example, you can say “I want to delete my personal information,” or “please provide me with access to my personal information.” We cannot begin processing your request until you have clearly stated which right(s) you wish to exercise.
  3. 3. Make sure to include your city and country of residence in your request. We cannot begin processing your request until you have confirmed your residence. We will only use this information in order to fulfill and document your request.
  4. 4. Repeat the above steps for any other games for which you would like to make a request.

If you have trouble with any of the steps described above, you can contact privacy@scopely.com for help. We may contact you to confirm your choices and to ask for additional information as needed to verify your identity and process your request.

We will never discriminate against you for exercising any of your rights under California law.

  • Contact Us

If you have questions or concerns about this Policy or our data practices, you can contact us by email at privacy@scopely.com, or by postal mail at: Scopely, Inc., Attn: Legal, 3530 Hayden Avenue, Culver City, CA 90232. If we receive a formal written complaint from you, we will attempt to contact you directly to resolve your concerns. If you have an unresolved privacy or data use concern that you feel we have not addressed satisfactorily, please contact our US-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.