Privacy Policy

Last updated:July 10, 2024

Roundy Games(“Roundy Games,” “we” or “our”) is committed to protecting the privacy of its users (“users” or “you”). This Privacy Policy outlines how Roundy Games collect, use, and share your personal information when you access or use our websites, our mobile applications (“Apps”), or any associated features, content, or pages owned or operated by us (collectively, “Services”) that link to this Policy. This Policy does not address the privacy practices of any third parties that we do not own or control.

By accessing and using the Service, you confirm that you have read, understood and agreed to this Privacy Policy. If you do not agree to this Privacy Policy or have concerns about providing information to us, you should not use our Services.

Roundy Games reserves the right to periodically modify this Privacy Policy. We encourage you to review the Privacy Policy from time to time for the latest information on our privacy practices. If we make any changes to the Privacy Policy, we will revise the date at the top of the Privacy Policy with an updated revision date. In case of material or significant changes, we may provide an additional notice (such as emailing you, or placing a notice on our website or in-game). Please note that your continued use of our Services will signify your acceptance of any updates to this Privacy Policy.

Personal Information we Collect

When you use any of our Service on a mobile platform, we may collect and process certain information.We may collect personal information from you directly, from third parties, from business partners, or from publicly available sources.

We collect the following types of data for the purposes stated below:

Cookies, SDK and Similar Technologies

Our Services use cookies, SDK and similar technologies to deliver essential and additional functions. Please seethe[Service Providers and the Partners]for more information on the types of SDKs we incorporate into our mobile applications.

• The information collected by the SDKs are for the purposes of:

• providing and improving our Services;

• analyzing how our Services are used by users;

• displaying and running in-app advertisements;

• studying and analyzing the functionality and performance of the Services and activities related to the Services;

• protecting the Services and usersfrom fraud, misuse and unlawful use of the Services’ and related data and assets.

We do not have access to the information collected by the SDKs.

Service Providers and the Partners

We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Services.

The below companies assist us by providing services relating to advertising and marketing. If you reside in the European Economic Area (“EEA”), the advertising networks, analytics providers, and other companies listed below may collect or receive device information from our apps on your browser or device for advertising purposes, including personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, the inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery, reporting, and optimize targeted ads. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple’s ID for advertising (IDFA). In addition, the advertising networks listed below are independent data controllers in respect of your personal information and you can learn more about how each handles your data or provides opt-outs by accessing their respective privacy notices using the hyperlinks below.

How We Use Your Personal Information

We will only use your personal information as described in this Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your personal information include:

To Provide OurServices

We use your personal information to provide you with the Apps and any other services, purchases or requests in connection with the Services you request. This may include processing transactions, providing you with the requested features, syncing your data across your devices logged into your account, and providing you with customer service.

To Personalize Your Experience

We may process your information to personalize the Services for you. For example, we use your language preferences and country location to display the correct language and time zone in the Services. We also use certain information about your device (such as operating system version and screen resolution information) to optimize the display of pictures on your screen.

To Send You Service-Related Communications

We will use your information (such as contact information) to send you communications about your account, requested transactions, and changes in our policies. Please note that you may not opt-out of such communications, which are necessary to keep you informed about important updates about your account and the Services.

To Conduct Analytics and Other Internal Purposes

We may use your personal information to conduct analytics. This can be used for quality control, internal auditing, and to measure how our Apps, Services, and ad campaigns are performing. We also use your personal information to accumulate and report aggregate statistical information in connection with the Apps, Services and user activity, in order to help us operate, enhance and improve our Services.

To Ensure Security of our Services

We may use your personal information for the purposes of identity verification, customer service, security protection, combatting spam, malware, and malicious activity, fraud monitoring, archiving and backups, ensuring the security of the Apps and Services that we provide to you.

To Conduct Research and Development

We may process your personal information to improve our existing Services and help us design new ones. When we do so, we may implement security measures and safeguards to protect the privacy of your personal information. For example, we may institute technical safeguards or administrative safeguards, such as restricting access to personal information to only those who need access to conduct the research and development functions.

To Promote Our Services

We use your personal information for our marketing activities. For example, we may conduct targeted marketing and send you information about our and our partners’ products, events, and market studies that may be of interest to you.

To Maintain Legal and Regulatory Compliance

Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, and to manage risk as required under applicable law.

How We Share Your Personal Information

We may share your personal information in the following circumstances.

1) With Our Service Providers

We may use third parties to perform certain functions on our behalf to provide you with the Services such as:

• to process payments and complete transactions you request, such as payments for our subscription service, which is processed by Apple (App Store) or Google (Google Play Store);

• to process and store data, including your personal information;

• to provide security for our Services; and

• to conduct market research.

We have agreements with third-party service providers in place to ensure they use adequate safeguards when processing your personal information.

2) Legal Obligations and Safety

We may disclose your personal information if it is reasonably necessary to:

• Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);

• Comply with valid requests or investigations by public authorities;

• Comply with applicable laws or regulations;

• Enforce our policies, agreements, and terms, whether in litigation, other disputes, or otherwise;

• Protect our legitimate interests, including legal interests;

• Protect the security or integrity of the Services; or

• Protect the rights, property, or safety of you, other users, employees, partners and affiliates, or other natural persons.

We will, at our discretion, provide you with advance notice if we are compelled to disclose your personal information to law enforcement, public authorities, or other governmental entities, unless we are prohibited from doing so by governmental entities or the law.

Your Privacy Rights and Choices

Your Choices

We may use your personal information to send you messages about new products and services, events, or other information that may be of interest to you, whether through email or other methods. If you do not wish to receive such information, you can change your account settings or click the “unsubscribe” button in email communications. Please note that you will not be able to opt-out of receiving non-promotional, transactional communications about your account or the Services.

Your Privacy Rights

Depending on applicable law where you reside or are located, you may be able to assert additional privacy rights identified below with respect to your personal information. If any of the rights provided to you under the law that governs your personal information, we have absolute discretion in providing you with those rights. Please refer to the “What Rights Apply” section to determine the rights you have in the jurisdiction you reside.

Please note, your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of the request is required or authorized by law; (b) when granting the request would have a negative impact on another’s privacy; © to protect our rights and properties; (d) where the request if frivolous or vexatious, or for other reasons.

• You may have certain legal rights in relation to processing of your personal data, which may include:

• Access right: you may request access to your personal data in our possession.

• Rectification right: you may request us to correct your personal data if it is inaccurate.

• Erasure right: you may request us to delete your personal data.

• Restriction right: you may request us to restrict how we process your personal data.

• Portability right: you may request us to help you transfer your personal data to other entities.

• Withdrawal of consent: you may withdraw your consent at any time.

• Right to complain and report: you have the right to complain to the relevant supervisory authority.

• The above rights may only apply in limited circumstances under the applicable law and if we decide not to respond to your claim for the above rights, we will explain reasons.

Children’s Data

Our Services are designed and provided to users of various age groups. We will not collect personal data from any users who are under the age of 13. If parents or legal guardians suspect that their children, under the age of 13, have provided us with personal data inadvertently, they may request such personal data be removed by contacting us at support@roundygames.com

Users who are between 13 and 18 years old (or the relevant age defined as a minor in the respective jurisdiction) should seek the consent of their parents or legal guardians before using our Services.

California Consumer Privacy Notice

If you are a California resident, this section applies to you in addition to the rest of this Privacy Policy. The California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, “CCPA”) requires us to disclose the following additional information related to our privacy practices.

1）Categories of Personal Information Collected, Used, and Disclosed

In the preceding 12 months, depending how you interact with our Services, we may have collect the following categories of personal information (as defined under Cal. Civ. Code §1798.140(v)(1)):

• Identifierssuch as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;

• Commercial informationsuch as records of products or services purchased, obtained, or considered by you, transaction records, and payment information;

• Internet or other electronic informationregarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;

• Geolocation data, to the extent you have configured your device to permit us to collect such information, and

• Inferences drawn from any of the information listed above, such as your shopping preferences, characteristics, and behavior.

We do not collect protected classifications about our users, biometric information, professional or employment-related information, or education-related information.

2) Purposes for Collecting and Using Categories of Personal Information

We collect and use your personal information for the following business purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage or similar services;

• Providing advertising and marketing services;

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;

• Helping to ensure security and integrity;

• Debugging to identify and repair errors that impair existing intended functionality;

• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us;

• Undertaking internal research for technological development and demonstration; and

• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

3) Your Rights and Choices

Right to Know

You have the right to request details about the personal information we collect, use, disclose, and sell, if applicable. This includes the categories of personal information, the specific pieces of information, the categories of sources from which the information is collected, the purpose for collecting or selling the information, and the categories of third parties with whom we share or sell that information.

Rights to Delete

You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions.

Right to Opt-Out

You have a right to opt out from future sales or sharing of personal information as those terms are defined by the CCPA.

Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this Privacy Policy may be considered a “sale” under those definitions. To opt-out from sales or sharing of personal information, please email your request to support@roundygames.com.

Right to Non-Discrimination

You have the right to not be discriminated against for exercising any of your CCPA rights. This means we will not deny you services, charge you different prices, or provide a different quality of service if you choose to exercise your rights under the CCPA.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send your request or confirm your request from the email address associated with your account or requiring you to provide information necessary to verify your account.

To exercise any of these rights, please contact us support@roundygames.com. We will respond to your request in accordance with the GDPR requirements.

Virginia Consumer Data Protection Act (VCDPA) Rights

If you are a resident of Virginia, the Virginia Consumer Data Protection Act (VCDPA) provides you with the following rights regarding your personal information:

Right to Access

You have the right to request access to the personal information we hold about you, including information on how it is processed.

Right to Correct

You have the right to request the correction of inaccurate or incomplete personal information.

Right to Delete

You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected or if you withdraw your consent.

Right to Data Portability

You have the right to request a copy of your personal information in a portable and readily usable format.

Right to Opt-Out

You have the right to opt out of the sale of your personal information or the processing of your data for targeted advertising purposes.

Right to Appeal

If we deny your request to exercise any of these rights, you have the right to appeal our decision. You can submit an appeal by contacting us at [insert contact details].

To exercise any of these rights or to appeal a decision, please contact us at support@roundygames.com. We will respond to your request or appeal in accordance with the VCDPA requirements.

Connecticut, Colorado and Utah Rights

If you are a resident of California, Connecticut, Virginia, Colorado, or Utah, in certain circumstances you have rights under the data protection laws of your state in relation to personal information we hold about you. We are fully compliant with the privacy regulations of these states. Should you wish to exercise any rights afforded to you, or have any questions, please email support@roundygames.com.

Additional Notice to Individuals in the European Economic Area, United Kingdom, and Switzerland

This section only applies to individuals located in the European Economic Area, United Kingdom, or Switzerland (collectively, the “Designated Countries”) at the time of data collection.

We may ask you to identify which country you are in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries

Data Security

We are committed to keeping your personal data safe. We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.

Data Protection Officer : Roundy Games’s IT team is responsible for data protection. For any questions or concerns regarding your personal information and how it is handled, you can contact our Data Protection Officer (DPO) at: support@roundygames.com.

Data Retention

How long we retain your information depends on why we collected it and how we use it. We generally retain your personal information as long as your account is active and for no longer than isnecessary for the purpose for which such personal information is processed. Please note, however, that we may retain and use your personal information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and reasonably feasible to remove such information from our databases. Consistent with these requirements, we will endeavor to delete your personal information promptly upon your written request.

Contact Us

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our data protection department at support@roundygames.com.