Contents

• About this Privacy Policy
• Consent
• Information We May Collect and How We Collect it
• How We Use Information
• How We Share Information
• Interest-Based Advertising
• Your Rights and Choices
• Data Retention
• Security
• Use By Minors
• Additional Information for Residents of the EEA, United Kingdom and Switzerland
• Additional Information for Residents of California
• External Linked Website
• Contact Us

 

1. About this Privacy Policy

 

Hello! Welcome to the DSW Gaming LLC Privacy Policy (“Policy”). This Policy describes how and when we may collect, use, secure, and share information collected in connection with our games, mobile apps, websites, content, products, and any related services (collectively the “Services”), and your choices regarding that information. For purposes of this Privacy Policy, “DSW Gaming” (or “we” or “us” or “our”) refers to DSW Gaming LLC and its parents, subsidiaries, representatives, affiliates, officers, and directors.

 

This Policy applies to all of our games, whether played on our website http://www.dswgaming.com, on mobile devices, PCs or on such other platforms.

 

Please read this Policy carefully. We may update it from time to time by posting a new version on https://dswgaming.com/privacy-policy/ with an updated date. If we make material changes, we will notify you, prior to the changes becoming effective, through the Services or by other means if you’ve provided us additional contact information (e.g., using the email address associated with your Account, as defined in our Terms of Service). Your continued use of the Services after the Effective Date will be an acknowledgement of our updated Privacy Policy.’

 

In addition, please review our  , which govern your use of the Services. By using our Services, you consent to this Privacy Policy and DSW Gaming’s Terms of Service and our collection, storage, sharing and use of your information and data, and other activities, as described.

 

2. Consent

 

By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to us and our advertising partners’ use of your data for targeted advertising purposes as described in the Interest-Based Advertising sections of this Privacy Policy. Those sections also explain how you can withhold or withdraw your consent to the use of your personal information for targeted advertising purposes. If you have any other concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services.

 

3. Information We May Collect and How We Collect It

 

We may collect various types of information, including information you provide or make available to us directly, information collected from your devices (including web and mobile) such as country, region, game play information, and information collected from other sources, like social networking sites and gaming partners. Some of this information may be considered “personal information” or “personal data” under applicable privacy or data protection laws.

 

Information You Provide

 

You may provide information directly to us when you:

 

• Use or access the Services, including when you create an Account (as defined in our Terms);

 

• Connect with or access our Services using a third-party ID or log-in, such as an ID for a social networking site or gaming service;

 

• Communicate with or contact others using our Services, including when you use chat, “invite a friend,” “email this page,” or other similar features;

 

• Contact us, including for customer or technical support;

 

• Participate in DSW Gaming offers, contests, or special events;

 

• Subscribe to newsletters or sign up to hear about current or upcoming products); and/or

 

• Complete surveys offered by us or on our behalf.

 

Depending on how you choose to use the Services, you may provide us with the following information:

 

Things like your first and last name, username or handle, third party service ID, email address, phone number, home address or shipping address, and other contact information.

Your photo, avatar or other image.

Your date of birth, and gender.

Other information such as chat records, friends’ names and contact information, and non-precise location information you choose to share (for example, when you connect with our Services through social features).

Information Collected or Generated When You Use our Services

 

When you access or use our Services, we collect information from and about you and the device(s) you use. This may include the following information:

IP address, unique device identifiers, advertising identifiers, device serial numbers, and similar identifiers.

Hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, or clickstream data.

Approximate location inferred from IP address.

Game scores and achievements, and other information as reasonably required to offer and enhance our Services.

Information Collected Using Cookies and Similar Technologies

 

We and our affiliates and partners may use cookies, beacons, software development kits, mobile analytics software, and/or similar technologies for a number of purposes, including to authenticate users, prevent fraud, remember preferences and settings, analyze advertising and messaging campaigns, analyze traffic and trends, personalize content (including ads), and otherwise provide the Services. These technologies may collect information about your use of our Services, pages you view, links you tap, messages you open, and other actions taken in connection with our Services.

Depending on the choices and settings available for the browser(s) you use, you may be able to disable cookies in your browser settings, but this could affect the availability and functionality of our Services. For information on interest-based advertising and how to opt out, see the Interest-Based Advertising section below.

Analytics:

 

On our Website or Mobile Application, we also may utilize Analytics Software, a web analysis service to better understand your use of the Website and Services. This software collects information such as how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. This software uses the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other services. This software may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network. Their ability to use and share information collected by the software about your visits to the Websites is restricted and controlled by their terms of service and privacy policy.

Game Analytics is the current software tool being used and you can find their Terms of Service and Privacy Policy here.

 

Please consult the applicable Website Cookie Notice for more information about the type of cookies and tracking technologies that we use on the Website and why, and how to accept and reject them.

 

Information Shared With Us Through Social Features

 

Some of our Services may incorporate features offered by social networks and other third-party sites, and in some cases, you may access our Services using single sign-in services like Facebook Connect. If you choose to take advantage of these features, we may collect additional information you choose to share with us, including the following:

Your name, user ID, social username, and contact information.

Your gender, age, date of birth, and language preference.

Other information such as time zone, the organizations and links on your profile page, the names of your friends or contacts, and other information you share in connection with your profile.

If you allow contact information to be shared with us, we may use that information to communicate with you or with your invited friends as described in this Privacy Policy and as further described at the time you choose to share that information (for example, we may suggest friends to play with, or may help you invite a friend to play with you).

Information Collected From Other Sources

 

We may also collect information about you from other sources, including from our third-party partners or service providers, publicly available sources, feedback from other players, or social networking sites as described below. We may combine this information with other information in our possession, which helps us to update, enhance, and analyze our Services, and provide tailored experiences for you.

4. How We Use Information

 

We may use the information we collect for a number of business and commercial purposes, including to:

• Perform internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing, and research;

 

• Understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns);

 

 

• Maintain the safety, security, and integrity of our Services, for example by authenticating users and providing account security and fraud detection;

 

• Send you news and/or marketing communications (by email), including information about DSW Gaming or third-party offerings we think may be of interest to you;

 

 

• Administer contests, surveys and sweepstakes you enter, and notify contest winners and award prizes;

 

• Facilitate your communication with friends and other users, and enable features that allow you to share information with other people (for example, if you choose to use friend invite features); and/or

 

• Comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Services.

 

 

5. How We Share Information

 

We may share the information we collect about you, and may enable you to share this information, with a variety of third parties in various ways, including:

• With vendors, consultants, business partners, and other third-party service providers as necessary to carry out work on our behalf and otherwise provide the Services;

 

• With other players, to enable you to interact with them and to share gameplay-related data such as high scores and other leaderboard information;

 

 

• With the general public, if you choose to share information when contributing content to our Services through a forum, blogs, social features, or the like;/

 

• Where you choose to take advantage of social sharing features or related tools that let you share games and other actions you take on our Services, with the public, social media platforms, and/or your social media friends or contacts;
• With others who share your device, if you make your Account available to them through that device;

 

• With specific third parties if we believe disclosure is required by applicable law, regulation, or legal process;

 

 

• With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our terms or other policies, and/or are fraudulent or in violation of applicable law, or as we determine necessary to protect the rights, property, or safety of DSW Gaming LLC or others;

 

• In connection with a merger, consolidation, restructuring, sale of company stock and/or assets or other corporate change, including during the course of any due diligence process; and/or

 

• In an aggregated form or otherwise in a form that cannot reasonably be used to identify you.

In some cases, we may enable you to access third-party products or services through our Services. Please note that those products or services are offered by people or companies not affiliated with or controlled by us, and we are not responsible for their actions, their terms, their use of information, or their products or services. If you submit your information to a third party, that third party’s treatment of your information is governed by their privacy policy, which may differ from this Privacy Policy and which we encourage you to review

We also share information with your consent or at your direction. For example, we may share your personal data if you opt in to receiving information from our business partners.

6. Interest-Based Advertising

 

When you play our games or use our Services non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the delivery of ads to your device.

We work with the following third-party advertising partners:

• Facebook (https://www.facebook.com/privacy/explanation)
• Google (https://policies.google.com/technologies/partner-sites)
• Admob (https://policies.google.com/technologies/partner-sites)
• AdColony (https://www.adcolony.com/privacy-policy/)
• Unity Ads (https://unity3d.com/legal/privacy-policy)
• Iron Source (https://www.is.com/privacy-policy/)

 

We may share certain of your information with these partners to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences.

If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.

If you prefer to opt out of having your web viewing behavior used for interest-based advertising, you can learn how to do so by clicking here, or if located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, by clicking here. If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may do so through your device settings (“Limit Ad Tracking” on iOS and “Opt Out of Ads Personalization” on Android). Please note that you may continue to receive generic ads that are not based on your preferences.

7. Your Rights and Choices

 

Right of Access

You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why.

Updating or Correcting Your Personal Information

You are expected to maintain accurate, complete, and up-to-date information in connection with your Account, but we provide you functionality to update or correct that information directly in-app. You can also access a range of information in-app, including things like your user name, picture or avatar, social log-in, game performance and progress, Virtual Items, chats, or other information you may have entered in-app.

Notwithstanding the above, please feel free to reach out to us via support@dswgaming.com, whenever, you intend to update or correct your information.

Deleting Your Personal Information

In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.

Communication Preferences

Email, phone, and text: We may contact you at the email address (es) or phone number(s) provided in connection with your Account. You may opt out of these messages by following the unsubscribe instructions in the message (e.g. by tapping an unsubscribe link).

Push: In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.

Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Other Rights

In some cases, particularly if you are a resident of the EEA, the United Kingdom, or Switzerland, or if you are a resident of the State of California, you may have additional rights with respect to your personal data or personal information as defined under applicable laws. For more information on these rights, please refer to the additional disclosures below.

8. Data Retention

 

We may retain personal information where required by law or where we have an ongoing legitimate business need to do so. For example, we may retain such information to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, enforcement of our contracts and terms, or for safety reasons (e.g., we may retain certain information about an Account to prevent that user from opening a new Account).

9. Security

 

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and only those at DSW Gaming with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to ensure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.

10. Use by Minors

We do not knowingly collect or process personal data from or about, or direct or target interest-based advertising to, anyone under the age of 13 (or under the age of 16 for those in the EEA, United Kingdom, or Switzerland), nor do we knowingly allow such individuals to use our Services. If you believe we might have any personal information from or about a child under this age, please contact us using the details provided on the last page. If we learn that we have inadvertently gathered such information, we will delete it.

11. Additional Information for Residents of the EEA, United Kingdom, and Switzerland

 

Rights and Choices Available to EEA Residents

If you are a resident of a member country of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you may have the following rights with respect to any information about you that constitutes “personal data” under EEA law:

Access your personal data: You may have the right to obtain confirmation regarding whether we process your personal data and obtain a copy of the personal data we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)

Rectify or correct your personal data: You may have the right to correct your personal data where it contains inaccuracies.

Request erasure (deletion) of your personal data: You may have the right to request that we delete your personal data in certain cases, for example when it is no longer necessary to fulfill the purposes for which DSW Gaming collected it. This right may be limited to the extent that DSW Gaming is permitted or required by applicable law to retain the data. (Note that if you request deletion of your personal data, you may no longer be able to use or access the Services. If you share devices with someone else who uses the Services, that person may also lose game progress or related account information and access. If you decide to use or access the Services again, we may consider this a new Account and may collect personal data associated with that Account in accordance with this Privacy Policy).

Restrict or object to the processing of your personal data: In certain cases, you may have the right to object to our processing of your personal data, or request that we restrict that processing. Because the data that we collect is generally required to provide the Services to you, if you object to the processing of your personal data, this may have the same effect as requesting deletion of this data. This right may be limited to the extent that DSW Gaming is permitted or required by applicable law to continue processing the data. (Note that if you object to the processing of your personal data, you and others who use your devices to access the Services may no longer be able to use or access the Services.)

Request a portable copy of your personal data: In certain limited cases, you may be able to request that we provide you with a copy of your personal data in a structured, commonly used and machine-readable format so that you can transmit it elsewhere.

To protect the privacy of your information, DSW Gaming verifies your identity and processes all rights requests through our in-game help ticket system. If you wish to exercise any of the rights described above, please send us an email via: support@dswgaming.com.

In addition to the rights described above, if we have collected and processed certain types of personal data with your consent, you may withdraw that consent in the manner described when you provided consent. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to then, nor will it affect any processing based on lawful grounds other than consent.

In some cases, you may have the right to file a complaint with a data protection authority about our collection and use of your personal data. For more information, contact your local data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.

Legal Basis for Processing Personal Data

 

If you are from the EEA, the United Kingdom, or Switzerland, our legal basis for collecting and using your personal data will depend on the type of information and the context in which we collect it. In general, we collect personal data from you only where we have your consent to do so, where we need it to perform a contract with you, or where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need it to protect your vital interests or those of another person. If you have questions about the legal basis on which we collect and use your personal data, please contact us.

Transfer of Personal Data from the EEA

 

DSW Gaming may transfer personal data from the EEA, the UK, or Switzerland to the United States, including personal information we receive from individuals residing in the EEA, the UK or Switzerland who visit our Website or download our game and/or who may use of our Services or otherwise interact with us. Please note that for individuals located in the EEA or the UK, the term Personal Information used in this notice is equivalent to the term “personal data” under applicable European and UK data protection laws.

When we engage in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or ii) Standard Contractual Clauses issued by the European Commission. The European Commission has determined that the Standard Contractual Clauses provide sufficient safeguards to protect the personal data transferred outside the EU or EEA. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. We also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.

 

12. Additional Information for Residents of California

 

Information We Collect, Use, and Disclose

Under the California Consumer Privacy Act (‘CCPA’), we are required to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in the “Information We Collect and How We Collect It,” “How We Use Information,” and “How We Share Information” sections of this Privacy Policy.

Generally, we collect the following categories of personal information, as defined by the California Consumer Privacy Act (‘CCPA’)

Identifiers and contact information, including first and last name, username or handle, third party service ID, IP address, unique device identifier, advertising identifier, device serial number, email address, phone number, home address or shipping address, and your friends’ names and contact information;

Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream data;

Demographic information, including your gender, age, date of birth, and language;

Non-precise geolocation information, such as approximate location as inferred from IP address;

Visual information, such as your profile picture and the profile pictures of your friends or contacts; and

Other information you may share if you use social features when accessing our Services, including the organizations, links, and other information included on your social profile pages.

Rights and Choices Available to California Residents

 

Under the California Consumer Privacy Act (‘CCPA’), California residents have certain rights regarding the personal information that businesses have about them. This includes the rights to request access or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.

The Right to Opt-out of Sale

 

We do not sell player personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We support the CCPA and wish to provide you with control over how your personal information is collected and shared.

You have the right to direct DSW Gaming to not sell your personal information and to exercise your right to opt-out by sending us an email via support@dswgaming.com.

Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual; we may also retain information as needed in order to comply with legal obligations, enforce agreements, and resolve disputes.

Right to Request Disclosure

 

You have the right to request disclosure about what categories of Personal DSW Gaming has sold or disclosed for a business purpose about you and the categories of third parties to whom the personal information was sold or disclosed. Additionally, you have the right to request disclosure of specific pieces of information. Below is a full list of the information that you can include in your request.

• The categories of personal information that DSW Gaming has collected about you.
• The categories of sources from which DSW Gaming collected the personal information.
• The business or commercial purpose for collecting or selling the personal information.
• The categories of third parties with whom DSW Gaming shares personal information.
• The specific pieces of personal information DSW Gaming has collected about you.
• The categories of personal information that DSW Gaming disclosed about you for a business purpose.
• The categories of personal information that DSW Gaming has sold about you, as well as the categories of third parties to whom DSW Gaming sold the information.

 

If you would like to exercise your right to request disclosure, please send us an email via support@dswgaming.com. Our privacy team will examine your request and respond to you as quickly as possible.

 

Right to Request Deletion

 

You have the right to request that DSW Gaming delete any personal information about you that DSW Gaming has collected from you. Please note that there are exceptions where DSW Gaming does not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.

If you would like to exercise your right to delete, please send us an email via support@dswgaming.com and our privacy team will examine your request and respond to you as quickly as possible.

 

The Right to Non-Discrimination

DSW Gaming will not discriminate against you (e.g., through deleting your account, or providing a different level or quality of services) for exercising any of the rights afforded to you.

 

California and Delaware “Do Not Track” Disclosures

 

California and Delaware law require DSW Gaming to indicate whether it honors “Do Not Track” settings in your browser concerning targeted advertising. DSW Gaming adhere to the standards set out in this Privacy Policy and does not monitor or respond to Do Not Track browser requests.

.

13      External Linked Websites

 

For your convenience, hyperlinks may be posted on the Websites that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy policy of each Linked Site that you visit to understand how the information that is collected about you is used and protected.

Contact Us

If you have questions or concerns about this Policy or our data practices, you can contact us by email at support@dswgaming.com, or by postal mail at:

DSW Gaming LLC.

Attn: ____________

7353 Layne Dr. Midvale, UT 84047

If we receive a formal written complaint from you, we will attempt to contact you directly to resolve your concerns.

 

Last Updated: August 4, 2021