PRIVACY POLICY

Effective Date: June 5, 2019

Introduction

FUERO Games Sp. z o. o. ("FUERO GAMES") develops and publishes social games for the web and mobile devices (the "Service"). In this policy, "FUERO GAMES" refers to FUERO GAMES and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We may also refer to FUERO GAMES as "We" or "Us".

This Privacy Policy describes:

• the information We collect, how We do so and the purposes of our collection
• how We use and with whom We share such information
• how you can access and update such information
• the choices you can make about how We collect, use and share your information
• how We protect the information We store about you

If you access our games from a third party Social Networking Site ("SNS"), you may be required to also read and accept the SNS Terms of Service and Privacy Policy.

Information We Collect

Information about You Received from an SNS

When you use any FUERO GAMES game at an SNS such as Facebook, Google +, etc., where our games may also be referred to as "applications", you allow FUERO GAMES to access certain information from your profile for that site. The information you allow FUERO GAMES to access varies by game and SNS, and it is affected by the privacy settings you and your friends establish at the SNS. You can control and find out more about these settings at the SNS where you play our games. For example, FUERO GAMES may access and store some or all of the following information, as allowed by you, the SNS and your preferences:

• your first and last name
• your profile picture or its URL
• your user ID number, which is linked to publicly available information such as name and profile photo
• the user ID numbers and other public data for your friends
• the login e-mail you provided to that SNS when you registered
• your physical location and that of your access devices
• your gender
• your birthday

By playing a FUERO GAMES game through an SNS, you are authorizing FUERO GAMES to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the SNS could provide to FUERO GAMES through the SNS Application Programming Interface ("API")

Information We Collect from You Directly

When you interact with the Service (whether or not on an SNS), at http://www.winionsgame.com/ or any FUERO GAMES-owned website, We may collect and store information from you directly as described below:

Registration Information

We may allow you to "register" with Us by using Facebook Connect or other SNS authentication options to create an account or profile within the Service. We may also provide a more typical registration flow where you may be required to provide the following information: your age or birthday (for age screening and/or to better understand who our users are); your first and last names; your e-mail address; a password and other information that helps Us confirm that it is you accessing your account.

We may also offer you the option to complete a user profile that is visible to other FUERO GAMES users. Your user profile may include: a profile photo; one or more game username(s); your gender; biographic details that you provide; links to your profiles on various SNS; details about the games you play; and a FUERO GAMES user ID number that is created by FUERO GAMES and used to identify your profile.

The FUERO GAMES user ID number used to identify your account and profile will be public and will appear in the URL of your profile page, but will only permit access to information that is considered public or that you have designated as public in your settings.

Your first and last names and profile picture are considered "public" on FUERO GAMES websites that offer direct access to FUERO GAMES games and search engines may index this publicly available information. When We offer profiles, We will also offer functionality that allows you to opt-out of public indexing of your public profile information.

Information We Receive or Collect When You Access FUERO GAMES Games on a Mobile Device

If you play FUERO GAMES games on your mobile telephone or other mobile device, including iPads and tablets, We collect mobile device identifiers, including MAC Address, and IP Address. In certain games We will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, geo-location or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Service.

Payment Information

If you purchase a license to use in-game virtual currency or virtual items directly from FUERO GAMES, We will collect the billing and financial information necessary to process your charges, which may include your postal and e-mail addresses. FUERO GAMES may also receive the billing and payment information that you provide when your purchase is processed by another party, such as Facebook (for Facebook Credits) or Apple (for purchases on iOS devices). Our Terms of Service explain our policies and terms relevant to our charges and billing practices. Please note that purchases of third party credits or currencies like Facebook Credits may also be subject to additional policies.

Customer Support Correspondence

When you ask for assistance from our Customer Support team, We will collect and store the contact information you provide (generally your name and e-mail address), information about your game play or activity on the Service, and your user ID number. We will also store the correspondence and any information contained within.

SMS Notifications, Push Notifications & Local Notifications

We receive and store the information you provide, including your telephone number, when you sign up to have SMS notifications sent directly to your mobile phone. These messages notify you of in-game activity and may allow you to play the game from your phone. You can adjust the types of notifications you receive and when you receive them by editing your SMS notification settings; just log in to your game account and choose SMS mobile from the Help menu.

With your consent We may send push notifications to your mobile device to provide game updates and other relevant messages. You can manage push notifications from the "options" or "settings" page within the relevant game. You may also be able to manage them from your device’s settings page for the relevant game.

We may send local notifications to your mobile device to provide game updates and other relevant information. You can manage local notifications from the "options" or "settings" page within the relevant game.

Technical and Usage Information

When you access our websites or play our games, We collect (i) certain technical information about your mobile device or computer system, including MAC Address, IP Address and mobile device ID; and (ii) usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files ("Log Files"), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number(s). For more information on how We utilize cookies and other tracking technologies please review the "Cookies and Automated Information Collection" portion of Section 3 ("How We Collect Information about You").

How We Collect Information about You

We may collect information about you in any one or more of the following ways:

Information about Players and Play

When you play one of our games, FUERO GAMES collects and stores certain information that you provide directly or through the SNS or other third party website that is offering our game(s). To provide a richer game play and social experience, We also collect information about your play and interaction with other players and the Service. The bulk of this information is collected and stored through the use of Log Files, which are files on our web servers that record actions taken on our games and websites.

Communications Features

You may be able to take part in certain activities on our websites or games that give you the opportunity to communicate or share information not just with FUERO GAMES, but also with other users of our Service. These include:

• participating in player forums and message boards
• posting public comments to other users' profiles or gameboards
• sending private messages or invitations to other users, either directly on our websites or to their e-mail accounts
• chat with other users
• posting photos

We may record and store archives of these communications on FUERO GAMES's servers to protect the safety and well being of our users and FUERO GAMES's rights and property in connection with the service. You acknowledge and consent to the recording and storage of such communications for these purposes.

Cookies and Automated Information Collection

When you access the Service, We collect certain technical information in order to (i) analyze the usage of our sites and services; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf, such as Google Analytics, use Log Files and tracking technologies to collect and analyze certain types of technical information, including cookies, IP addresses, device type, device identifiers, browser types, browser language, referring and exit pages, and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, game state and the date and time of activity on our websites or games, and other similar information. In some cases, We will associate this information with your user ID number for our internal use.

We may also employ other technologies including (i) web beacons, which allow Us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow Us to advertise more efficiently by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help Us to prevent fraud, remember your in-game preferences and speed up load times.

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit adobe.com and make changes at the privacy settings panel. If you disable cookies, you may lose some of the features and functionality of playing our games, as FUERO GAMES cookies are necessary to track and enhance your game activities. Please note that companies delivering advertisements in our games or on our websites may also use cookies or other technologies, and those practices are subject to their own policies.

Other Sources

We may collect or receive information from other sources including (i) other FUERO GAMES users who choose to upload their email contacts; and (ii) third party information providers. This information will be used to supplement your profile - primarily to help you and your friends connect. It will be combined with other information We collect.

How We Use the Information We Collect

In general, We collect, store and use your information to provide you with a safe, smooth, efficient, and customized experience. For example, We may use information collected from you in any one or more of the following ways:

• to create your game accounts and allow play of our games
• to identify and suggest connections with other FUERO GAMES users
• to enable user-to-user communications
• to provide technical support and respond to user inquiries
• to prevent fraud or potentially illegal activities, and enforce our Terms of Service
• to deliver and target advertising
• to notify users of in-game updates
• to provide in-game leader boards and promote in-game player achievements
• to solicit input and feedback to improve FUERO GAMES products and services and customize your user experience
• to inform users about new products or promotional offers
• to engage in commonly accepted practices, such as contacting you at the email address We have on file if you are a potential winner in a sweepstakes
• To provide you with marketing information (including personalized and targeted marketing emails), which we feel may interest you. For example, we may send you newsletters or emails about Fuero Games services (of course, this is optional and we will ask you for permission first when you use our subscription form.).

One important use of your information is communication. If you have provided your e-mail address to FUERO GAMES, We'll use it to respond to (i) customer support inquiries, and (ii) keep you informed of your in-game activity, including comments from friends, notifications about in-game status. Some messages, such as invites for friends to join you in a game, may include your name and profile photo. We may also send promotional e-mail messages and promotional SMS messages ("Promotional Communications") directly or in partnership with parties other than FUERO GAMES. Each Promotional Communication will generally offer recipients choices about receiving additional messages.

Sharing of Your Information

We will share your information (in some cases personal information) with third parties, that is parties other than FUERO GAMES, in the following circumstances:

Third Party Service Providers

We will provide your information to third party companies to perform services on our behalf, including payment processing, data analysis, e-mail delivery, hosting services, customer service and to assist Us in our marketing efforts. We direct all such third party service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on FUERO GAMES's behalf.

Friends and Other FUERO GAMES Players

The Service supports and may encourage interaction among players. In most FUERO GAMES games your SNS friends will see your name, profile photo and descriptions of your game activity. In many FUERO GAMES games friends and other players will be able to see your game profile, which may include your name or a "game name" and your profile photo, which in certain cases can reveal your SNS User ID number or FUERO GAMES ID. For example, in FUERO GAMES Poker any other player may encounter your game profile, if you are playing at the same table. Access to a FUERO GAMES ID or your SNS User ID may allow others to view the public information associated with your related SNS or FUERO GAMES account. Other players may also be able to send you game requests or even friend requests through the related SNS' communication channels.

Advertising of Third Party Products and Services

We do not actively share personal information with third party advertisers for their direct marketing purposes unless you give Us your consent.

We may share (i) aggregated information (information about you and other users collectively, but not specifically identifiable to you); (ii) anonymous information; and (iii) certain technical information (including IP Addresses, MAC Addresses for mobile devices and mobile device IDs) to develop and deliver targeted advertising in the Service and on the websites of third parties. We may also allow advertisers to collect these types of information within the Service and they may share it with Us. Advertisers may collect this information through the use of tracking technologies like browser cookies and web beacons. The information collected may be used to offer you targeted ad-selection and delivery in order to personalize your user experience by ensuring that advertisements for products and services you see will appeal to you, a practice known as behavioral advertising, and to undertake web analytics (i.e. to analyze traffic and other end user activity to improve your experience).

Our collection, use, and disclosure of anonymous or aggregated information are not subject to any of the restrictions in this Privacy Policy.

Offer Walls

FUERO GAMES games or their purchase pages may display an "offer wall" that is hosted by an offer wall provider. The offer wall allows third party advertisers to provide virtual currency to users in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These are not offers made by FUERO GAMES. These offers may be displayed to you based on certain technical information, such as your geographic area or anonymous demographic information. After clicking on one of these advertisements, you will no longer be on a site hosted by FUERO GAMES or a partnering SNS. To properly credit user accounts and to prevent fraud, a unique identifier, in some cases your user ID number, will be shared with the offer wall provider.

Safety, Security and Compliance with Law

Your information, and the contents of all of your online communications (including without limitation chat text, voice communications, IP addresses and your personal information) may be accessed and monitored as necessary to provide the Service and may be disclosed: (i) when We have a good faith belief that We are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any applicable laws or regulations (iii) where We believe that the Service is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) when We have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) in order to protect the rights or property of FUERO GAMES, including to enforce our Terms of Service.

Sale or Merger

In the event that FUERO GAMES undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, We may transfer all of your information, including personal information, to the successor organization in such transition. If material changes to FUERO GAMES's privacy practices will occur as a result of the business transition, We will notify you and other users (in the manner described in Section 12) of the business transition prior to transferring your personal information.

Our Policies Concerning Children

Our websites and games are not intended for children under the age of 13 and We do not knowingly collect any personal information from such children. Children under the age of 13 should not use our websites or games at any time. In the event that We learn that We have inadvertently gathered personal information from children under the age of 13, We will take reasonable measures to promptly erase such information from our records.

How to Access and Update Your Information

Information We Receive From an SNS Where You Play Our Games

To manage the information FUERO GAMES receives about you from an SNS where you play our games, you will need to follow the instructions at that site for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here. The privacy management tools for Google + can be found here. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of each application.

Once FUERO GAMES receives your information from an SNS, that information is stored and used by FUERO GAMES in accordance with this Privacy Policy, and you may access and update that information as described below. Game or other accounts created with FUERO GAMES are considered active until We receive a user request to delete them or deactivate them.

Other Methods of Accessing and Controlling your Information

• If you no longer want FUERO GAMES to make active use of your information, you may send an e-mail to: support@fuerogames.com Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and user ID number for the SNS from which you access our games (if applicable) in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content on the Service, We may not be able to delete it.
• If you wish to review or change the information FUERO GAMES has about you, e-mail Us at the address provided herein.
• You may change your e-mail preferences at any time, by visiting your e-mail preference page.
• You can turn off push notifications by visiting the "options" or "settings" page within the relevant game. You can turn off local notifications by visiting the "options" or "settings" page within the relevant game.
• You can stop further use of your geo-location (for example through "check-ins") by visiting your device's settings for the relevant application or the "settings" page for the relevant game. You can also stop checking in.
• If you have additional questions about this Privacy Policy, contact Us at: support@fuerogames.com

Your Sharing and Messaging Options

Information We Receive from Third Party SNS Where You play a FUERO GAMES Game

If you play our games at a third-party SNS, FUERO GAMES will be able to access and store profile and other information about you as described above. The categories of information you share with Us will depend, in part, on the permissions you grant Us and the privacy settings you have established at the SNS where you access the application. FUERO GAMES does not offer an "opt out" option for specific fields that are shared by the SNS where you access and play the game(s).

Opting out of Promotional Communications

You can choose to opt out of receiving additional promotional e-mails from FUERO GAMES by clicking on the "unsubscribe" link in any such e-mail, or visiting the e-mail preference page. Please note that once We receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, and in no event longer than 10 business days.

Opting Out of Other Communications

You can opt out of receiving SMS messages by texting STOP to the number We send from for that particular SMS program. In some cases a preference management page will also be available under the "Help" menu of the game that is offering the SMS program. When We receive an opt-out message from you for SMS messages, We may send a message confirming our receipt of your opt-out.

When you install our apps on your mobile device you can choose to receive push notifications. You can turn off push notifications by visiting the "options" or "settings" page within the relevant game. You may also receive local notifications. You can turn off local notifications by visiting the "options" or "settings" page within the relevant game.

Note that if you opt-out of our Promotional Communications or other forms of communication, We may still e-mail or communicate with you from time to time if We need to provide you with information or if We need to request information from you with respect to a transaction initiated by you or for other legitimate non-marketing reasons.

Privacy Policies of Linked Sites and Advertisers

Our websites and games may contain advertisements from companies other than FUERO GAMES that may link to their own websites. We are not responsible for the privacy practices or the content of such websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly.

Security of Your Information

FUERO GAMES implements reasonable security measures to protect the security of your information both online and offline, and We are committed to the protection of customer information.

For user accounts registered directly with FUERO GAMES profile information is protected by the password each member uses to access their online account. It is important that you protect and maintain the security of your account and that you immediately notify Us of any unauthorized use of your account. If you forget the password to your FUERO GAMES account, the website allows you to request that instructions be sent to you that explain how to reset your password. When you sign into your account or enter payment information (such as a credit card number when purchasing virtual currency), We encrypt the transmission of that information using secure socket layer technology ("SSL").

While We take reasonable precautions against possible security breaches of our websites and our customer databases and records, no website or Internet transmission is completely secure, and We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If your SNS account is hacked, this may lead to unauthorized play of your FUERO GAMES games, so be careful to keep your account information secure. If you have questions about the security of our websites, please contact Us at support@fuerogames.com

Unfortunately, the transmission of information over the Internet is not completely secure. Although We strive to protect your personal data, We cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once We have received your information, We have procedures and security features in place to try to prevent unauthorized access.

Changes to Our Privacy Policy

If We decide to make material changes to our Privacy Policy, We will notify you and other users by placing a notice on FUERO GAMES.com or by sending you a notice to the e-mail address We have on file for you. We may supplement this process by placing notices in our games and on other FUERO GAMES websites. You should periodically check www.FUEROGAMES.com and this privacy page for updates. 

Contact Us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to: support@fuerogames.com All other inquiries should be directed to FUERO GAMES's Support Page.

FUERO GAMES Sp. z o.o.

ul. Wita Stwosza 32/7

02-661 Warszawa

POLAND