Privacy Notice

Last Updated: August 6, 2020

Please read this Privacy Notice and Policy (“Policy”) carefully. It applies to all information Sociologic Games Limited and its affiliated entities (collectively “Company”, “we”, or “us”) collect from you through our web sites and game applications (collectively “Services”). Company is a developer and distributor of digital games via applications available on the Facebook platform, and via the app stores of Google, Apple, and Amazon.

This Policy describes:

· the information we collect, how we collect it, and why;

· how we use and share that information;

· how you can access and update that information;

· the choices you can make about how we collect, use, and share your information; and

· how we protect information.

We, Sociologic Games Limited, 16 Hanatziv Street, Tel Aviv, Israel, 6701806, or any of our affiliated entities notified to you from time to time, are the responsible controller of your Personal Information processed in connection with the Services.

If you have any questions or complaints about this Policy or want to assert any of your rights as set out below, you can contact us as follows:

Company's European Union ("EU") Privacy Representative:

https://www.verasafe.com/privacy-services/contact-article27-representative/

Alternatively, VeraSafe can be contacted:

In the Czech Republic:

Matthew Joseph Zahradníčkova

1220/20A Prague 15000

Czech Republic

In the Republic of Ireland:

VeraSafe Ireland Ltd.

Unit 3D North Point House

North Point Business Park

New Mallow Road

Cork T23AT2P Ireland
Phone: +1-617-398-7067

Company's Non-EU Privacy Representative:

gdpr@sociologicgames.com

Sociologic Games Limited

16 Hanatziv Street

Tel Aviv, Israel, 6701806

If you are located in the EU, you have the right to file a complaint against us through VeraSafe's Privacy Dispute Resolution Program: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

You are not under any statutory or contractual obligation to provide us with your Personal Information and any Personal Information is provided of your own free will. If you do not want us to collect, use, or share your Personal Information in the ways described in this Policy, you should not access or use the Services. If you do not provide us with your Personal Information as set out in this Privacy Policy, we may not be able to offer the Services to you. By accessing or using the Services, you expressly acknowledge and, if effective under applicable law, agree to the terms of this Policy and that we will process your Personal Information as specified herein.

For Israel the EU Commission has acknowledged that Israel has an adequate level of data protection that is equivalent to the EU. By using the Services, you acknowledge that your Personal Information will be stored in our databases and we will process and use your Personal Information in Israel and in the United States ("US"). Please be aware that the privacy laws and standards in these countries, including the rights of authorities to access your Personal Information, may differ from those that apply in the country in which you reside. We will transfer Personal Information only to these countries to which we are permitted by law to transfer Personal Information, and we will take steps to ensure that your Personal Information continues to enjoy appropriate protections. Please read on to learn more about how we protect Personal Information, including when we transfer Personal Information outside of the EU.

1. What is Personal Information?

"Personal Information" means any information that specifically identifies an individual such as a name, address, telephone number, mobile number, or e-mail address, or information about an individual that could be directly linked to such identifying information such as device IP address and geo-location information ("Device Information"). Personal Information does not include “Usage Information” (meaning anonymous site usage information such as visit statistics, page views, device type, etc.), unless such information is connected to your Personal Information.

Under the EU’s General Data Protection Regulation ("GDPR"), to the extent applicable, personal data is defined as: "any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person."

For purposes of this Privacy Notice, the term Personal Information includes personal data as identified in the GDPR, where applicable.

2. Information Collected on Our Services

2.1 Information You Provide To Us

We will ask you to provide your Personal Information required to set up your user account and provide the Services to you. You may further choose to provide additional Personal Information to us through or in connection with the Services, e.g. when you request information from us, contact us, or submit comments. If you do not want your Personal Information processed by us, please do not submit it.

You may also elect to participate in certain activities on our Services that let you publicly communicate or share information such as player profiles, message boards, chat or messaging features, or gifting/invitation-sending features. If you participate in these activities, we will collect and process any or all of the information you submit for the purposes set out herein and to the extent required to provide the Services to you, even if submitted through a player-to-player messaging system.

We will also collect and process your Personal Information when you access the Services through a social networking site, such as Facebook, or through Facebook Connect functionality, including any or all of the following information: your name; your profile picture; your social network ID number; your friends’ public profile data on the social networking site; your email address; your location; your gender; your birthday or age; and any other information that the social networking site chooses to share with us. If you access the public areas of the Services through a social networking site or application, we may post your profile information and picture as allowed by the social networking site. Please refer to the privacy notice of the respective social networking site for further details on how your Personal Information is shared with us.

Where required, we will obtain your consent prior to collecting and processing any Personal Information provided by you.

2.2 Information Collected by Automated Means

Whenever you use the Services, the Company, as well as any third-party advertisers and/or service providers, may automatically collect usage information and device information. The technologies used on the Services to collect usage information and device information may include, without limitation, web beacons and cookies. Web beacons (also known as Internet tags, pixel tags, tracking beacons and clear GIFs) are clear/transparent graphic images placed on a web page or email which gather usage information and device information. Cookies are data files placed on a device when it is used to visit the Services. When we refer to cookies, we also mean web beacons and other technologies that collect information in a similar way to cookies ("Cookies"). Please refer to our Cookie Policy (under section 7 below) for further information.

We also may supplement and combine the information we collect about you through the Services with other information we receive from third parties in order to enhance our ability to serve you, to tailor our content to you, and to market products and services to you. In those cases, we will apply this Policy to any Personal Information received, unless we have disclosed otherwise.

Where required, we will obtain your consent prior to collecting and processing your Personal Information by automated means.

3. How We Use your Personal Information

When you access or use the Services, we collect, use, share, and otherwise process your Personal Information as described in this Policy. We will use Personal Information and other information we collect through the Services:

· to provide the Services and information you request;

· to process your transactions through the Services;

· to contact you about your use of the Services;

· to respond to your emails, questions, comments, and complaints, and to otherwise provide customer service;

· to personalize and improve the Services, and to deliver advertisements, content, or features that match our users’ interests;

· to monitor and analyze usage information and otherwise measure the effectiveness of the Services;

· to send you confirmations, updates, security alerts, and support and administrative messages, to detect and prevent fraud, and to otherwise facilitate your use of, and our administration and operation of, the Services; and

· to notify you about important changes to our Services.

We may rely on a number of legal bases to use your Personal Information in these ways. These legal bases include where:

· necessary to perform the contractual obligations in our Terms of Service;

· necessary in order to provide the Services to you;

· you have consented to the processing, which you can revoke at any time;

· necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;

· necessary for the purposes of our or a third party's legitimate interests, such as those of other visitors or our vendors, which may include our legitimate interests in complying with our statutory obligations and preventing fraud or other criminal activities, provided that such interests are not overridden by your interests or fundamental rights and freedoms, ;

· you have made the information public;

· necessary in the public interest; or

· necessary to protect your vital interests, or those of others.

We will not use your Personal Information for taking any automated decisions which produce legal effects concerning you or significantly affect you.

4. What Personal Information do we share with third parties?

We will not share the Personal Information we collect from you through the Services with third parties, except as described in this Policy or in the Services. We may share non-Personal Information, such as Usage Information, with third parties. We may share your Personal Information with third parties in the following circumstances:

4.1 Third Parties Providing Services on Our Behalf

We may share your Personal Information with third parties that perform services on our behalf (or on behalf of our partners), such as companies that host or operate our Services; provide customer service; manage payments; and provide marketing services to us. Such third parties are obligated to maintain the confidentiality of your Personal Information, and only use it to provide services on our behalf and as directed by us.

4.2 Your Agreement to Have Your Personal Information Shared

While on our Services, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your Personal Information with a third party. If you agree to have your Personal Information shared in this way, your Personal Information may be disclosed to the third party and the Personal Information you disclose will be subject to the privacy policy and business practices of that third party.

4.3 Business Transfers

We may also share your Personal Information with our affiliated entities, and such entities may use your Personal Information in accordance with this Privacy Policy. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or a portion of our assets, Personal Information and any other information that we have collected through the Services may be disclosed to such entity as part of the due diligence process, and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours, and as such, may be sold or transferred to third parties. In the event of such a transfer, the acquiring entity will remain obligated to treat your Personal Information in accordance with this Privacy Policy.

4.4 Legal Disclosure

We may transfer and disclose information, including your Personal Information, to third parties to comply with any legal obligation; at the request of governmental authorities conducting an investigation or otherwise requiring disclosure (including without limitation to meet law enforcement requirements and for the purposes of national security); to verify or enforce our Terms of Service; or to otherwise protect the rights, property, safety, or security of us, the public and/or other users of our Services.

5. How Long We Keep Your Information

The amount of time we will retain your Personal Information depends on why we collected it and how we use it. We won’t retain your Personal Information for longer than we are allowed under applicable law, and otherwise, will not generally retain your Personal Information for longer than is necessary to accomplish our business purposes and protect our legal rights. Your Personal Information will be promptly deleted when it is no longer required for these purposes.

6. Your Rights as Data Subject; Your Access and Choices

At any point while we are in possession of or processing your Personal Information, you, the data subject, have the following rights

if you are located in the EU, or where otherwise the GDPR is applicable:

· Right of access – you have the right to request a copy of the Personal Information that we hold about you.

· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

· Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

· Right of portability – you have the right to have the data we hold about you transferred to another organization.

· Right to object – you have the right to object to certain types of processing such as direct marketing.

· Right to withdraw consent - if you have given us your consent for the processing of your personal data, you may withdraw your consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If you withdraw your consent, we will only continue processing your Personal Information where there is another legal ground or where we are legally required to do so.

· Right to judicial review: in the event that we refuse any of your above-specified requests, we will provide you with a reason as to why. You have the right to complain as outlined in this Policy.

· Right to lodge a complaint with a supervisory authority: if you are not satisfied with our response or believe we are not processing your personal data in accordance with applicable privacy laws you have the right to lodge a complaint with the competent data protection supervisory authority.

All of the above requests will be forwarded on should there be a third party involved in the processing of your Personal Information.

6.1 Accessing and Updating Your Information

If you want to review, change, or have additional questions and requests, e-mail us at contact@sociologicgames.com. We will normally respond to your request within ten (10) days. Depending on the nature and scope of your request, we may require that you confirm your identity by providing two of the following documents: birth certificate, passport, driving license, or utility bill showing name and address.

To manage the information we receive about you from a social networking site, like Facebook, where you access or use our Services, 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. Please log in to your Facebook account to manage your privacy setting.

6.2 Stopping Use of Your Information

If you no longer want us to make active use of your information, you may send an e-mail to contact@sociologicgames.com requesting deletion of your information. We will respond to your request within ten (10) days. Please note that certain records (for example those relating to customer service matters) will be maintained for legal and accounting purposes. Please also note that we may not be able delete all content you have posted through the Services (for example, in public forums), and we may not be able to delete all residual copies of information in our backup systems.

6.3 Opt-Outs

You may opt out of receiving marketing communications from us by sending us an e-mail at contact@sociologicgames.com, or by following the unsubscribe instructions in any marketing communication that you receive. Your opt-out request will normally be processed within ten (10) days of the date we receive it. Note that if you opt-out of marketing communications, we may still e-mail or communicate with you if we need to provide you with information about the Services, your transactions with the Services, or for any other legitimate non-marketing purposes.

When you install our apps on your mobile device you may receive push notifications from us, which are messages an app sends you on your mobile device even when the app is not active. You can turn off push notifications by visiting your mobile device's "settings" page.

When you have opted-in to receiving SMS messages (i.e. text messages) from us as provided in our Terms of Service, you can opt out of receiving the SMS messages by texting back STOP to the number we send the text from for that particular SMS message 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.

For further information on how to opt out of Cookies please refer to our Cookie Policy (under section 7 below).

7. Cookie Policy

7.1 Our use of Cookies

We use Cookies to recognize your logged-in state on Services, to understand what Service features visitors are interested in, to make the Services function for you, and to help your browsing experience and use of the Services feel more customized. If Personal Information is processed using individual cookies the legal basis is pursuant to Article 6 (1)(f) of the GDPR to safeguard our legitimate interests in the best possible functionality of the Services and to make visiting our Services effective and customer-friendly. We divide Cookies into categories depending on their function and purpose as described in the following.

First- and Third-Party Cookies

First-party Cookies are Cookies that we set on our Services and in connection with our content and advertisements that appear on third-party Services. Our Services may contain Cookies from third-party providers, so-called third-party Cookies. Please visit the websites of the third-party providers to obtain further information on how they use the Cookies. You can find information about the third-party Cookies on our Services in the description below.

Security and Authentication (Strictly Necessary Cookies)

Some Cookies are strictly necessary and vital to ensuring that the Services work properly for visitors, such as maintaining the security, safety, and integrity of the Services, authentication and logging into Services (including remembering permissions and consents you have granted), and ensuring the ability to securely complete transactions. Without these Cookies, our Services won't work properly. Accordingly, we are not asking you for your specific consent for those Cookies. For all other Cookies your informed consent is required.

Account and User Preferences (Functional/Persistent Cookies)

Some Cookies are used to remember your account and User preferences over time, such as remembering your account or keeping yourself logged in when returning to the Services, and maintaining your choices with respect to Service features, and customizing content based on how you use the Services. These Cookies remain on your device and enable us to recognize you the next time you use our Services.

Social Networks (Social Media Plugin)

Some Cookies help you to interact with social networks you are signed into while using the Services, such as sharing content with the social network, logging in with the social network, and other features you employ with the social network, or that are allowed in the social network’s privacy policy. These may be set and controlled by the social networks, and your preferences with those social networks.

Performance and Analytics (Analytics/Performance Cookies)

Some Cookies help provide performance data on how the Services are functioning in order to improve the Services, including, for example, data on site and app functionality and speed to help us optimize the Services, and detect and gather reports on bugs to help make the Services work better. These Cookies also help us understand how the Services are used by our visitors.

Marketing Services (Targeting Cookies)

Our Targeting Cookies are placed on your device by us (or service providers operating on our behalf). Additionally, we partner with third-party service providers that may use Targeting Cookies to permit us and them to learn about what ads you see and click when you visit the Services, or to show you ads on and off Services. These may include things such as:

· Frequency capping, which limits the number of times a user’s browser or mobile device displays the same ad;

· Attribution tracking, which estimates what advertising or marketing source brought someone to the Services, or determines what marketing source led to actions like a visit or a purchase;

· Remarketing, which shows relevant ads to an audience based on prior browsing patterns on Services;

· Audience targeting, which refers to targeting advertisements to a large audience based on the audience’s known or inferred demographics; and

· Cross-device recognition, which recognizes actions across multiple devices or browsers.

Some third-party service providers may provide information like demographics, cross-device information, or interest categories from a combination of sources that, while not identifying you personally, permit us to provide you with more relevant and useful advertising. In some cases, this information may have non-marketing performance analytics uses as well.

These technologies allow our partners to recognize your computer or mobile device each time you visit the Services based on data like a cookie, your IP address, or device ID, but do not allow access to other Personal Information from us. However, these technologies may allow us or a third party to recognize you, either from a single device or across devices, over time. These third parties are required to follow applicable laws, self-regulatory programs, and our data protection rules where applicable. However, we do not have control over these third parties, who each have their own privacy policies and privacy practices.

7.2 Cookies we use

The table below explains the Cookies we use and why.

Cookie	Cookie name	Purpose
Crashltycs		These Cookies are used to monitor technical crashes and exceptions.
Crittercism		These Cookies are used to monitor technical crashes and exceptions.
Databricks		These Cookies allow querying in game events that users are generating.
Facebook	fbp; fr	These Cookies are used to place advertising content onto Facebook that is relevant to you based on your browsing patterns on our Services. This information is never connected to your profile and it is always anonymous. Please follow this link for more information or to change your preferences on Facebook: https://www.facebook.com/help/568137493302217
Google Analytics	_ga; _gat; _gid	These Cookies are used to collect information about how visitors use our Services. We use the information to compile reports and to help us improve the Services. The information we collect is anonymous and is used to monitor the performance of our Services and to measure User engagement. We share the anonymised information with selected third parties to assist us in understanding the effectiveness of our Services and marketing. Please follow this link for more information on the Cookie and Privacy Policy of this third-party service provider: https://support.google.com/analytics/answer/6004245
Kochava		These Cookies are used for user acquisition tracking.
Singular		These Cookies are used for user acquisition tracking.

7.3 Options for managing Cookies

You are not obliged to accept a cookie and you can modify your browser so that it will not accept Cookies. Most internet browsers allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing Cookies; or (iii) to set your browser to automatically reject any Cookies.

Every browser differs in the way it manages the cookie settings. This is described in every browser’s help menu, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:

· Apple Safari

· Google Chrome

· Microsoft Edge

· Microsoft Internet Explorer

· Mozilla Firefox

· Opera

To find information relating to other browsers, please visit the browser developer's website.

Please be aware that certain portions of the Services may not work properly for you, or provide personalized or customized content, if you take these steps.

Aside from any specific opt-outs or general browser setting we have provided above, you can use the following options for managing Cookies.

You may opt out of Flash Cookie placement at http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html.

You can opt out of some third-party advertising programs that use your information. To do so, please visit the NAI Opt-Out Page: http://www.networkadvertising.org/managing/opt_out.asp. In order to opt- out of sharing your geolocation and other data with us from your mobile device, you can visit the "settings" page of your mobile device and review the information sharing permissions of each application or "app“.

We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral. Advertising (also referred to as "interest-based advertising") and respects the DAA's consumer choice tool for you to opt out of interest-based advertising at https://optout.aboutads.info.

If you do not wish to have your information used for the purpose of serving you interest-based advertisements, you may decline to receive interest based ads through TrustE/TrustArc's preferences manager (or if you are located in the EU click here). Please note this does not stop you from being served advertisements. You will continue to receive generic advertisements.

For Google Analytics Advertising Features, you can opt-out through Google Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI's consumer opt-out listed above). Google also provides a Google Analytics opt-out plug-in for the web.

If you access Services through our mobile applications, you may also control interest-based advertising on an iOS or Android device by selecting the "Limit Ad Tracking" option in the privacy section of the Settings App on iOS or via advertising preferences on Android-based devices (usually in the Google Settings app). This will not prevent you from seeing advertisements, but will limit the use of device advertising identifiers to personalize ads based on your interests.

8. Your California Privacy Rights

If you are a California resident and you decide that you do not want us to share your Personal Information with third parties for their marketing purposes, please send an e-mail to contact@sociologicgames.com. In this e-mail, state that you would like the Company not to share your Personal Information with third parties for their marketing purposes. Your opt-out request will be processed within thirty (30) days of the date of which we receive it.

Some web browsers incorporate a "Do Not Track" feature that signals to web sites that you visit that you do not want to have your online activity tracked. Please note that Company does not interpret or respond to "Do Not Track" signals.

9. Links to Other Sites

The Services may provide links to other web sites that we do not own or operate. We do not control, recommend, or endorse, and are not responsible for, these websites or their content, products, services, or privacy practices.

10. How We Protect Personal Information

We maintain certain administrative and technical safeguards to help protect against loss, or unauthorized access to or disclosure, of your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. We cannot ensure or warrant the security of any information you transmit to us, and your use of the Services is at your own risk.

11. International Operations; Transfers of Personal Information Outside of EU AND OUTSIDE OF ISRAEL

The Services are operated in Israel. We store Personal Information about players and visitors to our Services on servers located in the US. Please be aware that your Personal Information we collect will be transferred to and processed in Israel and the US. By using the Services, providing us with any Personal Information, or opting in to this Policy by means of any mechanism we provide, you acknowledge and, if effective under applicable law, agree to the collection, processing, maintenance, and transfer of such Personal Information in and to Israel and the US in which the privacy laws may not be equivalent to those in the country where you reside and/or are a citizen.

When we transfer your Personal Information internationally we will take reasonable steps to ensure that your Personal Information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

To the extent that we are deemed to transfer Personal Information outside of the EU, we rely separately, alternatively, and independently on the following legal safeguards to transfer your Personal Information:

11.1 Model Clauses

The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for Personal Information that is transferred outside of Europe. We often use these Model Clauses which are available here when transferring Personal Information outside of Europe.

11.2 Necessary for the performance of the contract between You and Us

We provide voluntary Services; you can choose whether or not you want to use the Services. However, if you want to use the Services, you need to agree to our Terms of Service, which set out the contract between us and our Service users. As we operate in countries worldwide (including in the US) and use technical infrastructure in Israel and in the US to deliver the Services to you, in accordance with the contract between us, we need to transfer your Personal Information to Israel and to the US as necessary to provide the Services.

12. Children

The Services are not directed to children under 18. We do not knowingly collect Personal Information from anyone under 18 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information.

13. Updates to Our Privacy Policy

This Policy may be updated periodically and without prior notice to you, and any changes will be effective immediately upon the posting of the revised Policy through the Services. However, we will use your Personal Information in a manner consistent with the Policy in effect at the time the Personal Information was collected, unless you consent to its use in accordance with a new or different version of the Policy. We will always indicate at the top of this Policy when it was most recently updated.

14. How to Contact Us

If you have any questions or comments about this Policy, please contact us at contact@sociologicgames.com.

15. Governing Law

This Policy shall be governed by and construed and enforced in accordance with the laws of the State of Israel without reference to its conflict of law provisions.