Kingsify LLC Privacy Policy
Last Revised: July 13th, 2021

This Privacy Policy describes:
     - The ways we collect personal data about you and why we do so
     - How we use your personal data, and
     - The choices you have about your personal data.

This Privacy Policy applies to Kingsify's games, websites and related services, which we here collectively call the Service. By using the Service, you agree to the collection, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not want Kingsify to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play Kingsify's games or use our Services. Kingsify may amend the Privacy Policy from time to time, and Kingsify encourages you to consult the Privacy Policy regularly for changes.


THE DATA WE COLLECT
Data you provide us.
     - Contact information(such as name, email address, phone number, mailing address)
     - Player name
     - Profile information (such as profile photo)
     - Your messages to the Service (such as player support email and chat logs)
     - Social Media Content. We may offer social media pages. Any content you provide on these channels will be considered "public" and is not subject to privacy protections.
     - Account Creation with Third-Party Partners. While you don't need to create a user account with Kingsify LLC to use our Services, including playing our mobile games, please note you may need to create a user account with our third-party partners for use of certain in-app features. When you create such an account, our third-party partners may collect certain personal information about you such as your name, email address, and payment information. Please refer to our third-party partners' Privacy Policy(https://www.skillz.com/privacy-policy/) for more information on the use and collection of the personal information you provide them. 
     - Other data you choose to give us (such as data to identify a lost account)

Data we collect automatically.
     - Data about your account and game progress
     - Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
     - Data about your device, such as device name and operating system, browser type and language
     - Data we collect with cookies and similar technologies (see more below)
     - General location data
     - Precise geo-location data (GPS, with your consent)
     - Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

Data we collect from our partners.
     - Data we receive if you link a third party tool with the Service (such as Facebook, Apple, Amazon, Samsung, Google, Skillz)
     - Demographic data (such as to determine the coarse location of your IP address)
     - Data to fight fraud (such as refund abuse in games or click fraud in advertising)
     - Data from platforms that the games run on (such as to verify payment)
     - Data for advertising and analytics purposes, so we can provide you a better Service


WHY DO WE COLLECT YOUR DATA
To make the Service work. In order to perform the contract, we process data necessary to
   - Create accounts and allow you to play our games and use our Service
   - Operate the Service
   - Verify and confirm payments
   - Provide and deliver products and services you request
   - Send you Service-related communications
   

To make the Service more suitable for our players. In order to provide a great Service to our players, we have a legitimate interest to collect and process necessary data to
   - Update and develop player profiles
   - Develop and improve the Service and player experience
   - Manage our relationship with you
   - Provide social features as part of the Service
   - Customize your Service experience
   - Respond to your comments and questions and provide player support
   - Provide you offers in the Service as well as in other websites and services, and by email
   - Send you related information, such as updates, security alerts, and support messages
   - Enable you to communicate with other players
   - Enforcing our terms and policies
   - Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
   - Developing new products and Services

To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to
   - Track the content you access in connection with the Service and your online behavior
   - Deliver, target and improve our advertising and the Service
For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.

To keep the Service safe and fair.
Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the Kingsify Terms of Service. In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to
   - Analyze and monitor use of the Service and its social features
   - Moderate chats either automatically or manually
   - Take action against fraudulent or misbehaving players

In all of the above cases and purposes, we may analyze, profile and segment all collected data With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.


WHO CAN SEE YOUR DATA
Apart from Kingsify, your data can be accessed by others in the following situations:
      - Other players and users. Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
      - Partners working with Kingsify. Kingsify has partners to perform services for us. These partners process your data only at and according to Kingsify's instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.
      - Other companies and public authorities. In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
      - Advertising and Social Media partners. The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
      - Disclosure in the Event of Merger, Sale, or Other Asset Transfers.  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. 


INTERNATIONAL DATA TRANSFERS
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy.


YOUR RIGHTS AND OPTIONS
     - Opt-out of marketing emails and other direct marketing. You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
     - Opt-out of targeted advertising. You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android).
     - Access the personal data we hold about you. If you request, we will provide you a copy of your personal data in an electronic format.
     - Your other rights. You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings. We will respond to all requests within a reasonable timeframe.  If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us.


COOKIES AND SIMILAR TECHNOLOGIES
Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.


HOW DO WE PROTECT YOUR DATA
    - Security Safeguards. In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
    - Data retention. We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.


AGE LIMITS
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child's account.


CONTACTING US
For any questions about its Privacy Policy or any other issue please contact Kingsify LLC at:
hello@kingsify.com