Personal Data provided by you directly.

When you use our Services, you may provide or be asked to give us certain information, including:

·         Age information: When you use our Services for the first time or sign up for an account, we ask you to enter your age for the purposes described below. 

·         Your account information: When you create an account on our Services, we collect your log-in data (your nickname/avatar name and/or your email address and password) and may collect additional profile information (entry of this information is entirely voluntary and not necessary to sign up for an account. You can edit or delete your profile information at any time) provided by you to personalize your profile (such as your first name, your selection of the avatar’s gender, and your avatar). This information will be combined with your User ID. Please note that you can use our Services as a visitor. In that case, we only require your nickname and device identifier which will be combined with your User ID.

·         Data provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details.

·         Data provided in response to surveys or another research we conduct.

·         Data submitted by participating in group communications or chats.

·         Other information that helps us make sure it’s you who is accessing your account, including as necessary for us to provide the support you request.

 

Personal Data you generate when using of our Services.

 

When you use our Services, we may also process device-related information and information about how you interact with our Services, including:

·         Technical information: The information we obtain from your device(s) includes the type of your device, IP address, device IDs, game/site ID, geolocation data (based on your IP address), browser settings, screen resolution, battery status, free storage, and other technical information.

 

·         Your usage: We collect information about how you use our Services. This information includes the actions you take within the game (e.g. if you win or lose a game, your achievements (such as the level reached), the items purchased within our Service, the amount you spent in the game, your friend list), the time and duration of your activity. Part of this information will be stored in your account (such as your friends list and your progress). Furthermore, we collect information about the websites that led you to our Service.

 

 

 

Personal Data we get from third parties

 

In certain scenarios, we will also obtain your Personal Data from third parties. For example, your Personal Data may be provided by the following third parties:

·         Payment Providers: If you make an in-app or website payment, the transaction will be processed by a third-party payment provider and will be subject to third-party payment providers’ privacy policies. For these transactions, we do not receive any specific financial information (such as your credit card information) but may receive basic information which is related to your transaction, for example the payment amount and payment date.

 

·         Social Networks and connected third-party platforms: If you choose to connect our Service with your e.g. Facebook, Apple, Plinga, Google, Microsoft, Steam, Samsung Galaxy or Huawei account by using your e.g. Facebook, Google, Microsoft, Steam, Samsung Galaxy or Huawei credentials within our log-in process, we may receive certain information about you like e.g. your name, you profile picture, your email address, and your friends list. If you enter our Services from a third-party platform, and you have created an account on the third-party platform or connected your game account with that platform, your username and your avatar may be shared with us to create your Service account. Furthermore, the third-party platform provider may share with us e.g. the platform ID, the avatar url, your email address, and your friends list. To manage the information, we receive about you from those third-party platforms where you receive our Services you will need to follow the instructions for each such third-party platform for updating your information and changing your privacy settings. Any personal data that will be processed by that third-party platform are subject to that third-party platforms’ terms of service and privacy policy.

For example, Playtika may collect and store some or all of the following information shared by the third-party:

·         your first and last name;

·         your profile picture or its URL;

·         your user ID number (like your Facebook ID number), which may be linked to other information like your name and profile photo, and your friends’ identifiers;

·         your friends list, which includes the user ID number and other information of your friends, like their names and profile photos;

·         the login e-mail you provided to the third-party application;

·         your approximate physical location (the country/state you are located in) and that of the devices you use to access our Service;

·         your gender;

·         your birthday and/or age;

·         information about your activities on or through the third-party application;

·         other information you have shared on the third-party application;

·         any other information that you or the provider of the third-party application share with Playtika.

·         User acquisition companies: If you click on our advertisements shown to you in a third-party network, we will receive campaign information (the campaign ID, clicks on our ads, creative views), information about installs of our Services, your country and language, and technical identifiers (Advertisement Device ID) from our user acquisition partners.

·         Other third parties: We may also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.

Cookies and Automated Information Collection

Playtika, our service providers, and third parties may place cookies on your device when you access or browse the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes. Information contained in a cookie may be linked to personal data. We may use cookies for purposes such as improving the quality of Playtika’s Service, making the Service easier to use, tailoring recommendations to interests and serving targeted ads. Third party advertisers may also use, place, or read cookies or other technologies as described below on your device, and those practices are subject to their own policies.

As further described in our Cookie Policy (”Cookie Policy”), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Policy.

How We Use Personal Data

Depending on which Service you are using and which privacy settings you have selected, we may Playtika may use personal data for a variety of business purposes as described in this Privacy Notice such as:

Provision and improvement of our Services

·         to allow you to use our Services.

·         to facilitate in-game communication via chat or web forum

·         to create and manage your account or to restore your account if you ever lose access.

·         to communicate with you in context of account activation and password management, to simplify the registration process.

·         to facilitate your purchase, to verify and confirm your payment to facilitate content sharing on social networks.

·         to provide technical support and respond to your requests.

·         to identify and correct any bugs/errors.

·         to indicate the popularity of our Services to assess the quality of our Services.

·         to understand and improve your online experience.

·         to pay our business partners for the promotion of our Services

·         to understand usage of our Services across all our group companies to support strategy and growth.

Personalization of your game experience

·         to remember your preferred game settings

·         to remember you next time you visit one of our Services.

·         to show you more engaging in-game promotions and offers

·         to provide you with a more personalized game experience

Marketing and analytics

·         to show you advertisements for our Services on other websites or apps

·         to measure the effectiveness of advertising and optimize it

·         to send you marketing communications, including newsletters and push notifications, informing you about new content and in-game offers

·         to acquire new users including on social media platforms

Prevention of fraud and illegal activity

·         to investigate fraud and illegal behavior in our Services and reporting it to relevant authorities

·         to enforce our policies and Terms of Use

·         to authenticate and/or verify individual identities.

·         to protect the safety and well-being of our players.

·         to protect Playtika's rights and property in connection with our Service including to enforce our policies and Terms of Service.

·         to address technical issues and maintain and/or enhance network and information security.

·         to conduct audits, ensure internal quality control, and take safety precautions.

 

Compliance with our legal or regulatory obligation

·         to determine the legal requirements for processing of your Personal Data (based on your location and your age)

·         to maintain records related to purchases.

·         to respond to your requests related to your data subject right.

·         to comply with our legal obligations (e.g. tax and accounting obligations) to inform you about any changes to this Privacy Policy.

 

 

 

 

 

Finally, we may use technologies that (a) may be considered automated decision-making or profiling, and/or (b) artificial intelligence to evaluate personal data that we collect including, for example, to create user segments, based on in-game activity (e.g. in-game purchase activity, the level reached in the game) for legitimate business purposes. We will not use these technologies in a way that has a legally significant impact on you, unless we have your consent, or we are otherwise legally permitted to do so.

For specific information about the user segments we create, see the section with service specific information below.

We may use personal data for any other purposes communicated to you at the point of collection, or otherwise with your consent.

Legal basis

We process your Personal Data for the purposes described in this Privacy Policy, based on the following legal grounds:

·         Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, we ask for your consent for the data processing in the context of our newsletter. We may also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your in-game settings. Please note that this will not affect any processing carried out before you withdraw your consent.

·         Performance of a contract: We process your Personal Data for the performance of a contract to which you are party, for example, where it is necessary for the creation and administration of your account, to process your in-game purchase and the associated payment, to support the operation of our games or facilitate the delivery of requested services.

·         Compliance with legal obligations: to which we are subject: We process your Personal Data to comply with legal obligations, for example, to verify your age, for tax and accounting purposes or legal disputes as well as any requests or claims from legal authorities.

·         Legitimate interests: We may also process your Personal Data to the extent that the processing is necessary for our legitimate interests. For example, we process your Personal Data for improvement of the Service provided to you, to provide you with a better user experience.

HOW WE SHARE PERSONAL DATA

We may disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

·         External service providers: We may share your Personal Data with external service providers who perform services on our behalf, like customer support services, IT services, hosting and content delivery services, web/social analytics services, data management services, user notification and marketing services, analytics services and forum hosting services. Where we share your Personal Data with external service providers, we have appropriate agreements in

 

place to ensure that your Personal Data is processed in compliance with applicable data protection laws.

·         Group companies: We may share your personal data with our group companies including Playtika Ltd and Playtika Holding Corp. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.

·         Payment providers: If you make in-app or website purchases, the transaction will be processed by a third-party payment provider and will be subject to the third-party payment providers’ privacy policies.

·         Social networks and connected third-party platforms: If you wish to share certain content on social media, you will be asked to log-in with your social media platform credentials. In this case, the content you want to share (e.g. a screenshot from the game) will be sent to the respective social network or third-party platform. If you signed up with your third-party platform account, we would send your account identifier and request data (e.g. user name, e-mail, profile picture) from the third-party platform provider. We have included a Google Play Games and Apple Game Center login on our mobile Services to enable you to integrate with your gaming profiles as and when they see fit to do so. Such parties may capture some of your data once you logged in. Please note that logging-in to these services is not mandatory but available in order to offer you more interaction in the mobile environment. For example, when you accomplish Google Play Games or Apple Game Center achievements, this will be visible on your Google or Apple profile, and you earn “experience” points and can increase your level to compete with other Google or Apple users. These parties are controllers of the data for their own purposes, so we strongly advise you to review their privacy policies. Furthermore, your Facebook ID and/or the advertisement ID may be shared with Facebook Inc. (Facebook) or Snap Inc. (Snapchat) in connection with Facebook’s and Snapchat’s ”Lookalike Audience” and ”Custom Audience” (re)marketing features which we may use for our Services. Learn more about our marketing activities in the service specific section below.

·         User acquisition companies: We may provide advertisements for our Services to user acquisition companies which show these advertisements on their websites or in their networks. If you click on advertisements shown to you on a third- party website or in a third-party network, you will be redirected to the app store where you can install our Service. The information about the installs of our Service, your country and language, the campaign ID, your user ID, and post install events (such as session time, reached level), including any purchase events and the purchase segment), may be shared with the user acquisition company.

·         Law enforcement, government authorities or courts: We may disclose your Personal Data in response to lawful requests from public authorities, including law enforcement, government authorities, supervisory authorities or courts. We may also disclose your Personal Data to legal authorities where we believe such disclosure is necessary for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights. In addition, we may also disclose information to protect the rights or property of Playtika and other applicable third parties, including to enforce our Terms of Service.

 

 

·         Sale, Merger or Changes in Structure: We may also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings). We will make reasonable efforts as described in this Privacy Notice to let you know of the business transition before transferring personal data to the extent required by law.

You can find a list of third parties your Personal Data may be shared with for each Service by clicking on the following link.:

Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find a list of third parties your Personal Data may be shared with for each Service by clicking on the following links:

MONOPOLY Poker

 

 Please note that the information on the above link may be changed or updated from time to time.

Children’s Privacy

In accordance with the Terms of Service, you may not use the Service if you are under 21 years old.

Playtika is committed to complying with laws protecting children. If you believe that your child has submitted personal data to Playtika, please contact us at [email protected].  Playtika will take reasonable steps to delete such information as soon as possible.

Cookies: While you cannot use our Services without registration, you can still enter the Service Websites which may allow us to collect your Personal Data through the use of cookies. When you access our game for the first time via Service Websites, you will be asked to confirm your age. For this age-confirmation method, we will also use your device or browser language data for presenting the age-gate in the correct language.

 

International Transfers

Playtika may transfer personal data to our subsidiaries, vendors, business partners, and others as described in this Privacy Notice.

Laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in place where you live. When we transfer personal data outside of the location where it was collected, we put into place appropriate safeguards (including, for example, contracts) or otherwise make efforts to ensure that such transfers meet applicable local legal requirements.

 

 

Playtika may send, access, use, and/or store personal data outside of the country or region where you live including, for example, to the United States and Israel. By using the Service, you consent to the transfer of personal data outside of the country or region where you live. If you do not consent to such transfer, please do not use our Service.

Security

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

We take reasonable steps designed to protect personal data; however, no system or network can be guaranteed to be 100% secure and therefore we cannot guarantee the security of data. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure.

Retention

We may retain personal data for as long as you use the Services and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.

Afterwards, we will delete or anonymize your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

YOUR RIGHTS

Depending upon the applicable law where you live, you may have the right to make requests with respect to personal data that Playtika processes about you, for example to request:

•   information.

•   access.

•   correction (or rectification) of personal data that you think is incorrect;

•   erasure (or deletion);

•   an electronic copy (or portability).

Object certain processing activities.

 

 

You may withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the processing based on consent before its withdrawal.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority in the place (country and/or state) where you live.

A.     Manage Information We Get from Platforms

To manage the information Playtika receives about you from a third-party platform where you play our games, like Facebook, Apple, Amazon, etc. you will need to follow the instructions for the relevant third-party application(s) for updating your information and changing your privacy settings.

B.     Choosing not to receive Promotional Communications

If you want to stop receiving Promotional Communications, you can click on the "unsubscribe" link in any promotional email from Playtika. If you want to stop receiving texts or SMS messages from us, you can also use the “unsubscribe” link or reply “STOP” to any promotional message. Please note that it may take us some time for your opt-out to become effective.

D.     Choosing not to receive Facebook messages.

If you want to stop receiving messages through our game pages on Facebook, you can turn off all messages through your Facebook “settings”.

E.     Choosing not to receive Push Notifications.

When you install our apps on your mobile device, you can choose to receive push notifications, which are messages an app sends you on your device even when the app is not on. You can turn off notifications by visiting your mobile device’s “Settings”.

G.     Choosing not to apply Cookie Tracking.

On Playtika websites that use cookies, you can use the cookie banner or click on the “Cookies Settings” link, to choose your preferences.  

You can set your web browser to warn you about attempts to place cookies on your device or limit the type of cookies you allow.

If you disable cookies, you may lose some of the features and functionality of our Service.

H.     Do Not Track.

Note that Playtika does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.

 

HOW CAN YOU CONTACT US?

If you have any questions, comments or concerns about our Privacy Notice or any other privacy issue please contact Playtika’s DPO office at [email protected] or Chief Privacy Officer, 8 Hachoshlim St., Herzliya Pituach 4672408 Israel.

If you have any questions or concerns that you think we have not adequately addressed, you may have the right to bring your question or concern to the privacy authority in the location where you live. 

Updates

Playtika reserves the right to amend the Privacy Notice from time to time, and Playtika encourages you to consult the Privacy Notice regularly for changes.

If we make material changes to our Privacy Notice, we will tell you by placing a notice on this website or its equivalent in-game, or, if and as required by law, by sending you a notice to the e-mail address we have on file for you, prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other Playtika websites. You should periodically check  this privacy page for updates.

Links to Other Sites/Apps

The Services may include links to other websites and/or applications that are owned and/or operated by others. Any information you provide on such websites and/or apps are subject to the privacy policy on such website or app, and Playtika is not responsible for the content, privacy policy, terms of use, or security practices of such site and/or app. You should review the terms and privacy policy of any site or app that you access.

Supplemental U.S. State Laws Notice ("Supplemental Notice”)

Playtika uses and shares information as described in this Privacy Notice. The information below supplements the Privacy Notice and is intended for consumers from select U.S. states, including California, Virginia, Connecticut, Utah and Colorado in accordance with applicable state laws.

Collection and Use of Personal Information

"Personal Information" in this Supplemental Notice refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a certain consumer or household or as otherwise defined under applicable law.

The following chart lists the categories of Personal Information we collect about players, the source of

 

collection, and the business purposes for collection. These are also the categories of Personal Information we collected in the past 12 months and their business purposes.

A more detailed description of the particular pieces of information we collect, and their purposes is provided in this Privacy Notice.

Category of Personal Information	Categories of Sources	Commercial or Business Purpose
Identifiers, such as picture, account name, device ID, email address, IP address, etc.	Players Players’ Devices Data Services Service Providers	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition
California Customer Records (Cal. Civ. Code § 1798.80(e)) such as telephone number and payment information	Players Data Services Service Providers Social Network Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition
Protected Classification Characteristics, such as age and gender	Players Service Providers Social Network Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing Detecting/Protecting against security events Player acquisition
Commercial Information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Players Data Services Service Providers Social Network Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing Detecting/Protecting against security events Player acquisition
Internet/electronic Network Information, such as website or application or advertisement browsing history	Players Players’ Devices Data Services Service Providers Analytic Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition
Location Data, device shared location, and Wi-Fi connection location	Players Players’ Devices Data Services Service Providers	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition
Inferences such as derivation of information, data, assumptions, or conclusions from any of the above categories of personal information	Players Players’ Devices Data Services Service Providers Social Network Services Analytic Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development / improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition

 

The following describes the categories of personal information we have shared for a business purpose in the past 12 months.

To the extent this practice is interpreted to constitute a “sale” and/or “sharing” under relevant state laws, Playtika permits, subject to legal and technical limitations, certain third-party advertising partners to collect information about our players through our games and our website for purposes ad campaign measurement and analytics, and for ad fraud detection and reporting.

To Whom We Disclose Personal Information

As described in this Privacy Notice, we disclose personal information within the Playtika group of companies and with a variety of recipients for business purposes.

In addition to the categories of recipients identified in the How We Share Personal Data section of this Privacy Notice, we disclose personal information to, or allow access to personal information by, the following categories of recipients:

•   Cloud Storage Providers

•   Payment and Auditing Processors

•   Security Safety Vendors and Service Providers

•   Customer Service Vendors

•   Advertising and Marketing Partners

Playtika provides opportunities, where appropriate, for players to opt-out of the use and sharing of personal data about them for this purpose.

You may reset these identifiers from within your mobile device or limit ad tracking for your mobile device as mentioned above.

Additional Rights

As referenced in Section 4 (“Your Rights”), you may submit a request to exercise certain rights through the Playtika Privacy Portal or through the Support page within the game you play. We will respond to your request in consistent with applicable laws and subject to adequate verification. We will verify your request by asking you to provide information necessary to verify your account.

You will not be discriminated against for exercising any of your rights. Please understand that, if the exercise of your rights limits our ability to process personal data (such as a deletion request), we may no longer be able to provide you with the Service.

You may appeal our decision regarding your rights request by sending an email to [email protected]. We will review and arbitrate the appeal based on applicable laws.

Minors

As described in our Privacy Notice, we do not knowingly collect or share personal data about children.

Authorized Agents

You may be allowed to use an authorized agent to submit requests on your behalf, if you provide sufficient information to show that the requestor is an authorized agent with written permission to act on your behalf and you verify your identity with us.

Service Difference

In each of the following instances, which we occasionally offer on some, but not all games, we may grant you virtual currency or other virtual items within the game:

Service Difference	Categories of Personal Information Collected	How to Opt-In to the Service Difference, if and when offered
In-game videos	Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn	Watch in-game videos that may be presented to you
In-game tailored ads	Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn	Consent to be served with ads that are tailored to your personal information and to sharing your personal information with ad networks, social media companies and other third-party businesses in the ad ecosystem
In-game surveys	Identifiers, protected classification characteristics, commercial information, Internet or other electronic network activity information, location data, inferences drawn	Complete a survey that may be presented to you about you and your game experience
Reviews about the game	Identifiers, location data, inferences drawn	Follow the instructions that may be presented to you to submit a review about the game, or rate the game, in an application store such as Google Play
Facebook connect	Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn	When offered to you, connect to our games through your Facebook account
In-game friend invitations	Internet or other electronic network activity information, commercial information, location data, inferences drawn	Invite your friends to download and play the game by sending an invitation from within the game, if prompted to do so
Connect to our game	Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn	Connect to play the game at the frequency indicated to you
Join our Facebook bot	Identifiers, Internet or other electronic network activity information	Connect with us through our Facebook bot
Mailing list	Identifiers	Subscribe to our mailing list when promoted

 

You have a right to withdraw from the service difference at any time. To do so, please submit a request through the Support section in the game settings or contact us via email to [email protected].

 

 

 

 

 

 

 

 

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed for each Service. For general information about data processes that apply to all Services, please see above.

Hosting and content delivery

MONOPOLY Poker is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Age gating and consent

When you visit MONOPOLY Poker for the first time, we will ask you to fill in your age. We use your age data to ensure that only adults play MONOPOLY Poker and that no personal data belonging to minors is processed except for those data that is strictly necessary to make the website work. Data about your exact age is not stored in this context.

Creation/administration of your account

In order to play MONOPOLY Poker, you have to create an account . We store your log-in data (your nickname, email address and password) to allow you to log in on different devices, based on the performance of a contract. If you choose to register using your e.g. Facebook, Google, Windows or enter our game from a third-party platform (e.g. Facebook, Steam or Google), we receive certain information about you from the respective third-party provider like e.g. your name, you profile picture, your email address, and a list of your friends that also play the game. This information will be stored in your MONOPOLY Poker account. If the third-party platform has an achievements system to measure and show you your achievements in the games you play, and only if you have provided your consent to the third-party platform provider, we will send event data (for example, that you reached a certain level in MONOPOLY Poker) to the third-party platform provider so that this information will also be stored in your profile on the third-party platform. If you choose to register using your Facebook account, we may receive certain information about you from the respective third-party provider like e.g. your name, you profile picture, your email address, and your friends list. This information will be stored in your MONOPOLY Poker account.

You can delete your MONOPOLY Poker account at any time, for example by submitting a deletion request to our support team using the contact feature within the game or by contacting our Data Protection Officer by email to [email protected].

 

Customer service

If you contact us for customer support using the contact feature, an external customer service provider will process the content of your request. In a first step, we will provide you with general information from our ”Frequently Asked Questions” feature (FAQ), based on the key words from your request. For example, if you have asked for information related to your account (e.g. on how to make changes in your account settings), we will suggest articles from our FAQ which contain account-related information (e.g. on why your account was blocked or on how to disconnect your MONOPOLY Poker account from Facebook). If the suggested articles from our FAQ do not contain the information you were looking for, we may ask you to provide your name and your email address in order to help you with your request.

This information will be processed together with your user ID (including segment), the last steps taken within the game, and device data (such as device model, battery status, free storage, device language, operating system version, carrier and platform). The request history will be stored in order to solve newer requests based on the information related to your previous request(s). Please note that if the request and correspondence with customer support is considered to be necessary for prevention of a crime, facilitation of an investigation related to public safety, protection of the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights, we may store and share your request based on legal obligation. We process this data on the basis of the performance of a contract in order to provide you with our customer service.

Analytics

We use analytics services to understand which features you like in MONOPOLY Poker and how you use them. For this purpose, we process purchase events (the amount spent within the game), the purchase segment, the level you reached within the game, your session time, which saloons you played in, how many hands you played, whether you won or lost the game, the features you used, and how many friends you have in the game. We combine this information with campaign data (including the advertisement device ID, installs data, your country and language, the

 

campaign ID, and your user ID) to get an insight into campaign results and to create user segments for new user acquisition and remarketing purposes.

The use of analytics services also helps us to improve the game for you, to find crashes and issues in the game, and to improve the performance of our websites/apps. For this purpose, we process crash information, ANR information (the situation if the game freezes), and device information (battery, Wifi situation, CPU, memory).

We also use Facebook Insights , an analytics service provided by Facebook and implemented through the Facebook SDK which allows Facebook to collect your Personal Data when you play MONOPOLY Poker. Facebook’s analytics service combines your in-game data (such as the level you reached and the amount you spent within the game), the purchase segment, campaign data (creative views of and clicks on advertisements, advertisement Device ID, installs, your country and language, the campaign ID and your user ID), the session amount and session time, with demographic data (for example your age, gender, country or language and likes) that Facebook knows from your Facebook profile. Facebook Insights provides us with aggregated information about our users which help us to improve our game and to adapt our services and ads to our target audience.

Social media sharing service

You may share content from MONOPOLY Poker with your friends via social media by clicking on the social media share button and using your social media platform account. Following your request, a screenshot from the game will be shared with the social media platform you wish to share your content with. We process this data based on your consent, which you provide by choosing to use the option to share content from MONOPOLY Poker via social media.

Data management service

We create user segments and use these user segments for new user acquisition and remarketing purposes . The user segments are created based on your in-game behavior (such as your in-game purchases, your sharing activity, and the level you have reached within the game) and by determining the spending behavior for each segment. For this purpose, your Personal Data, including your in-game behavior, your country, game language, segmentation and the advertisement ID are collected and sent to a data management service provider.

 

New user acquisition, remarketing and campaign tracking

The following processes help us to find new users, remarket existing users and measure the effectiveness of our advertisements:

New user acquisition: In order to acquire new users, we create advertisements (banners/videos) for MONOPOLY Poker and provide our advertisements to third-party user acquisition companies which show our ads in their apps or on their websites. If you click on the banner/video shown to you in a third-party app or on a third-party website, you will be redirected to the app stores (Google, Steam or Apple) where you can install MONOPOLY Poker. The information that you have clicked/viewed the advertisement (campaign information) will be sent from the user acquisition companies to an attribution platform provider (Appsflyer) and will then be passed by Appsflyer to the app store. If you install MONOPOLY Poker, the campaign information will also be passed from the app store to us and will be processed to measure the effectiveness of our advertisements . When you start playing MONOPOLY Poker, we collect and share post install events (for example, the level you reached within the game and purchase segments) either through the Appsflyer SDK or directly with the user acquisition companies which helps them optimizing their services.

The described data processing activities help us to track and optimize our campaigns and to reward our user acquisition partners and are based on our legitimate interests.

Furthermore, we use Facebook’s ”Lookalike Audience” feature to find new users based on the user segments we have created for our user base. In order to allow Facebook to search for a ”lookalike audience”, we select certain  segments give a list of these users' Facebook IDs and Advertisement IDs to Facebook. Facebook processes this information to check the Facebook profiles of the respective users for common characteristics of these users (for example, hobbies or the user’s location, using data available only to Facebook and which is not shared with us) and to find similar new users ('lookalikes') which are likely to be interested in our game. These similar users will be shown advertisements (banners/videos) for MONOPOLY Poker to encourage them to click the advertisements and install MONOPOLY Poker through the app-store.

Remarketing: We also provide our advertisements to third-party user acquisition companies to show advertisements for MONOPOLY Poker to existing users and to encourage them to come back to the game. For this purpose, if you are a registered user, we will share your user ID, your country and language with third-party user acquisition companies. Furthermore, we will share in-game data (for example, the level you reached within the game and purchase events and segments) either through the Appsflyer SDK or directly with the user acquisition companies to help them optimizing their campaigns.

 

Campaign validation and fraud prevention: In order to prevent fraud and analyze our campaigns we send campaign data we receive from our user acquisition partners in connection with the acquisition of new users (views, clicks and installs, campaign ID) together with analytics reports relating to the game usage to our internal user acquisition service.

This processing is based on our legitimate interest to optimize our marketing performance.

Push notifications

Based on our legitimate interests, we may show you push notifications on your device to inform you of new content and offers in MONOPOLY Poker. For this purpose, a user notification service will process information about the status of the push notification (notification received/viewed) and device information. You can turn off the push notifications in your account settings at any time.

Newsletters

When you sign up for an account in MONOPOLY Poker, you will be asked to provide your consent for the delivery of newsletters. In this context, we may process the following Personal Data such as your email address, your last log-in, your name, language, country, your user ID. You can cancel your subscription to our newsletter at any time over the corresponding link which appears at the end of every newsletter (or opt out through the in-game settings).

Payments

If you make in-game purchases, you will be redirected to an external payment provider for the transaction of your payment. While we do not collect and do not receive any financial data (such as your bank account data), we collect or may receive from third-party payment providers the following information related to your transaction: the quantity of the product you purchased, the product name, your user ID, the payment ID, the price, the currency symbol, your country, the receipt, product ID (sku), and the operating system.

We process your Personal Data in connection with your payments on the basis of the performance of a contract in order to facilitate your in-game purchase.

Chats

If you use the chat feature within the game, your messages will be stored in the game database and in our log system where it will be deleted after 2 months whereas your message history within the game database will be stored unless it is overwritten by newer messages.

This process is based on the performance of a contract in order to provide the forum and chat features within MONOPOLY Poker.

 

 

 

Logging of all in-game actions

In order to help you with any issues you might have with our game, we store all the steps you take within MONOPOLY Poker in our logs which will be deleted after two months.

This process is based on our legitimate interest to be able to analyze and solve any potential issue with our game.

Third parties

If you click here, you will see an overview of the third parties we may share your Personal Data with, or that may share your Personal Data with us.