Your privacy is important to IPlay. IPlay operates various websites with game-related products and services (our “Sites”) and provides applications for the provision of various online and mobile services, such as search and gaming (collectively, “Applications”) through which personal information may be collected. This privacy policy (the “Privacy Policy”) applies to all personal information collected by IPlay through our Sites and Applications.

If IPlay is operating the Sites or Applications under an agreement with a specific partner, the branding of the Site or the Application will indicate the specific partner with which IPlay operates the Site or Application (“Identified Partners”). In such an event, IPlay may share the data collected with that particular identified Partner. Accordingly, IPlay’s use of your data is subject to our Privacy Policy – and our Identified Partner’s use of your data is subject to its privacy policy. You should familiarize yourself with such Identified Partner’s privacy policy. Some of IPlay’s Identified Partners serve their own ads or use other ad-serving networks. To opt out of data collection by an Identified Partner’s ad-serving network, please see that Identified Partner’s privacy policy.

This Privacy Policy describes our practices regarding the information collected online through Sites and Applications maintained by IPlay, and not to websites or services offered and operated by other companies or organizations to which we link. Additionally, this Privacy Policy does not cover information that we collect through other methods, such as mail-in sweepstakes.

IPlay is headquartered in the United States and the collected data is stored in the United States. Although we operate Sites and maintain some operations outside the United States, when you become a member of one of our online communities or programs, make a purchase from IPlay or register for one of the Applications, your account is with a United States company and your data will be stored in the United States. By registering and using this Site, Members acknowledge that the processing of their personally identifying information for the purposes described above may involve the transfer of such personally identifying information from within the European Economic Area (“EEA”) to countries outside the EEA whose data protection regulation may not be as stringent as that within the European Union.

In accordance with the EU General Data Protection Regulation (GDPR), this Privacy Policy contains information about the personal and usage data IPlay collects about each user, and how that information is collected, stored and managed.

To request your personal and product usage data, or have your data/account removed, please email [email protected]

BY USING THIS SITE, APPLICATION, OR USING ANY OF THE RELATED SERVICES, YOU SIGNIFY YOUR ASSENT TO IPLAY’S PRIVACY POLICY AND YOUR UNDERSTANDING THAT IPLAY MAY PROCESS YOUR DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE FOREGOING, PLEASE DO NOT USE THE SITE OR APPLICATION OR IF ALREADY A MEMBER YOU MUST TERMINATE YOUR ACCOUNT.

THE INFORMATION WE COLLECT

If you are a visitor to a Site or a user of an Application, you may provide us with two types of information: personal information you knowingly provide us with on an individual basis (“Personal Information”) and statistical and usage information collected using cookies and other technologies as you browse the Site or use an Application (“Usage Information”).

1. Personal Information

Registration Information

You will need to provide us information about yourself, your firm or company, and your preferences when you register on one of the Sites or for one of the Applications. The specific information collected will vary depending on the Site or Application, includes your email address and/or username (or player name), . Registration is not required to browse any of our Sites, but you will not be able to view certain content or use aspects of certain Sites or Applications that require registration if you do not provide the requested information.

Credit Card Information

If you choose to purchase products or services from us or our partners, you will need to provide a valid credit card number, postal code, expiration date, and Security Code (CVV), in addition to email address and billing address IPlay securely transmits Credit Card Information to our payment processor for verification and processing, and never stores your full credit card number, expiration date or Security Code For subscription purchases, IPlay stores the last 4 digits of your credit card number, used for account, billing and purchase verification, and displays this in your secure Account page on the IPlay website and in the IPlay Games Manager application For all transactions, IPlay employs secure servers and the secure server software (SSL) to encrypt all payment information. In all instances, IPlay has made a substantial investment in server, database, backup, and firewall technologies to protect the assets of the Site, including the confidentiality of information collected about Members. These technologies are deployed as part of a sophisticated security architecture and protocol.

Email Information

In addition to providing us with your email address as part of registration, if you choose to correspond with us via email or by using a web interface to reach customer support, we may retain the content of your messages together with your email address and our responses.

2. Usage Information

Similar to other commercial websites, we utilize standard technologies such as “cookies,” clear GIFs (also known as “web beacons” or “action tags”) and web server logs to collect information about how the Sites and Applications are used. Additionally, when you connect to or download an Application, we may retrieve information from the computer used to log onto the Application. The information we collect may include technical information about your computer, system and application software, and peripherals, and any data related to the use and operation of the software used in connection with the Application.

Cookies

As an important and necessary part of providing customizable and personalized services to our Members, IPlay sites or its advertisers may use cookies, web beacons, and similar technologies to store and sometimes track non-personal information about Members while on the Website. A cookie is a small amount of data that is sent to a Member’s browser from a Web server and stored on a Member’s computer hard drive. Areas of IPlay sites where Members are prompted to log in or that are customizable require acceptance of cookies. These technologies are also used to help IPlay track the response to messages sent to Members on the part of marketers so that IPlay can monitor and report campaign results to the marketer and track response history and campaign effectiveness. In addition, banner advertisements are displayed on our websites which may contain certain cookies. While IPlay uses cookies in other parts of our websites, the cookies received with banner ads are collected by our advertising partners, and IPlay does not have access to this information. Members may opt out of the advertising that they see on our sites targeted specifically to them by going to the respective sites’ privacy policy(ies) and following directions. To opt out of Google’s “interest-based ads” and to learn more about Google’s collection of personal information to serve ads in connection with IPlay, please go to www.google.com/settings/ads/onweb/. With respect to cookies, users have a choice. By modifying their browser preferences, they have the choice to accept all cookies; they will be unable to use those IPlay services that require the use of cookies in order to participate.

Tracking Pixels

Tracking Pixels are small, invisible graphic images (usually only one pixel) placed on a web page or email message to capture statistical usage information. They are not used to collect personal information about you.

IP Addresses

An IP address is a number assigned to your computer every time you are connected to the internet. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that appropriate data (such as the web pages you request) and geographically relevant content can be sent to you.

Hardware ID

IPlay stores the hardware id, a unique identifier associated with the PC computer you use to access our websites and Applications, to determine a unique user within our systems. The hardware ID allows IPlay to determine if multiple accounts have been created on the same PC, and to prevent attempts by a single user or household to receive introductory offers to our subscription program(s) multiple times by using different email addresses or credit cards during registration and checkout. multiple accounts or using multiple credit cards.

The hardware ID may also be associated with any activity the user has taken in the context of a marketing campaign, such as viewed a promotional page, installed the Download Games Manager Application, initiated a game download, created an account or created a subscription, or canceled the a subscription.

Customer ID

When a user creates an account on the IPlay system, that user is assigned a Customer ID, which is displayed in the Personal Information section of My Account. The Customer ID gives the user a fixed non changing identifier that stays with their account from point of creation.

When a user registers on the IPlay system, a single sign on account is created, and a unique user identity (uuid) is generated at this point in time and saved in the user’s database record. This uuid does not change over time, unlike other personal data such as email address, postal code and credit card information. The Customer Id is thus connected to an end user’s account, and by extension can be used to find the user’s current:

If a user has multiple accounts within a single website or multiple websites operated by IPlay, each account has a unique Customer ID.

ADVERTISING

Our Advertisers

IPlay’s advertisers and advertising vendors display targeted advertisements. Although we do not provide any personal information to the advertiser or advertising vendor, by interacting with or clicking on an ad you acknowledge the possibility that the advertiser may assume you meet the targeting criteria used.

In addition to cookies placed by IPlay or its agents as described above, advertisers and advertising vendors that serve ads onto our Sites may use their own cookies or other tracking technologies. We cannot be responsible for the privacy policies or practices of any such advertisers and vendors.

HOW WE USE THE INFORMATION

Uses of your Personal Information

IPlay will use your information primarily to provide you with our products and services and to receive payment from you. In order to do this, we may determine whether you meet the minimum system requirements to use our products. We may also ask you to participate in surveys about products, services, news, and events; we may offer you product upgrades and games for you to purchase or access through a paid subscription service. You may opt out of some of these uses.

IPlay may also provide Personal Information to companies we engage as contractors or agents to perform services for us, such as maintaining software, providing email marketing, or administering a sweepstakes or contest. Information will be shared with contractors only to the extent reasonably necessary for them to perform these services on our behalf, and pursuant to confidentiality obligations. Members should note that IPlay may change this Policy at any time, and therefore IPlay may in the future store some information for additional purposes not currently included in this policy.

Uses of Usage Information

Usage Information may be used by IPlay to analyze Site and Application use in order to optimize the Site and the Applications and improve the user experience.

IPlay may use the information collected from your computer related to technical aspects of your connecting to a Site or Application in order to facilitate the provision of software updates, product support, and other services to you (if any) related to the Sites and Applications, to verify compliance with the terms of the applicable Site or Application, to improve our products or services or to provide Services or technologies to you.

IPlay uses third-party tracking services to measure the effectiveness of our marketing and advertisements to prospective customers and customers who have used our services. These services do not obtain or store any personally identifying information, but do record user activity at an anonymous level, such as pages viewed, buttons clicked, Games Manager application and game installs, account registrations and subscriptions created. Third party services may assign a unique user identification number for these events, but this will not be associated with any personal information provided to IPlay by the user.

GENERALLY

Where is the information held?

We are a global organization and the computer systems on which we collect, store, and use the information collected or received are based in the United States and elsewhere. Your personal information may be transferred to , used, processed, or held by IPlay in the United States and in other countries, including both member and non-member countries of the European Union, and used for the purposes set out in this Privacy Policy.

Third-Party Disclosure of Personal Information

IPlay does not use your Personal Information for the purposes incompatible with those listed above. Other than as provided in this Privacy Policy, IPlay does not provide your Personal information to third parties unless you specifically consent to provide such information to a third party. Sometimes, certain indirectly identifiable information needs to be communicated with third-party vendors, for example, to process an order you have made. We may also disclose Personal Information when legally compelled to do so. In other words, when the law requires it or when we have reason to believe that a disclosure is necessary or appropriate to address potential or actual injury or interference with the rights, property, or operations or IPlay, our users or others. Finally, if we undergo a merger or acquisition, or sell or otherwise transfer substantially all the assets of IPlay, or relating to any website that we own or operate or any product or service that we offer, Personal Information may be transferred to our successor or assign.

Selected Notifications

Occasionally we may also use the information we collect to notify you about new services, products and special offers we think you will find valuable. We will send you this type of communication only if we have received your permission to do so.

IPlay collects and may use the following data for Marketing via Email or on Social Media Websites such as Facebook, Twitter or Instagram. This data may only be used for advertising and marketing purposes by IPlay, and is not provided to any third party data collection or marketing services.

+ Email Address

+ Subscription Status (ACTIVE, CANCELLED, EXPIRED, DELINQUENT, none)

+ Purchaser Status

+ Names of games purchased

+ Name of games played

+ Number of games played

+ Total Minutes played

+ Subscription Start date

+ Subscription Cancellation date

+ Subscription Expired date

+ Last Login Date

+ Last Purchase Date

+ Zip or Postal Code

+ Country Code

IPlay uses MailChimp a third-party Email Service Provider, to send emails to customers who have opted in to receive email notifications about our products and services. Constant Contact provides IPlay with the following information for each email address within each of our email marketing lists. A unique user may appear in more than one email marketing list if the user has opted-in to such lists:

+ Email Marketing Status (Subscribed, Unsubscribed, Cleaned)

+ OPTIN Time

+ OPTIN IP Address

+ CONFIRM IP Address

+ Latitude for the IP address of the CONFIRM_IP.

+ Longitude for the IP address of the CONFIRM_IP.

+ GMTOFF The number of hours to add or remove to UTC time to get to the time zone for that contact.

+ DSTOFF The number of hours to add or remove to UTC time to get to the contact’s timezone, taking into account hours lost or gained due to daylight savings time.

+ TIMEZONE/CITY

+ LAST_CHANGED The date and time when information in the contact’s profile was last changed or updated.

+ LEID and EUID

Member Activity Rating may be used in email marketing to target content or promotions to subscribers based on their history of activity opening or clicking on emails from IPlay.

IP addresses and timezones may be used in email marketing to target content and promotions to users in various geographic locations. Users who have opted-in to receive notifications from IPlay may unsubscribe at any time via a link in the footer of the email, or by contacting IPlay Customer Support. Once the user has unsubscribed from a list, the Email Marketing Status for the user will change to “Unsubscribed” and IPlay will not contact the user again via that list. Constant Contact will continue to store the user’s email address, personal information listed above and campaign activity in the list. If the user wishes for any or all personal information to be removed from the list, the user may click on a link in the email’s footer to update their email subscription profile or request this by contacting IPlay Customer Support.

IPlay understands that a user’s interest in our products and services may change over time. Once 12 months has passed since the last date a user has opened an email from IPlay or one of its partners, IPlay will remove the user’s email address and personal data from the Constant Contact system. How Does IPlay Protect Your Information and Secure Information Transmissions?

We use industry standard technology and services to protect and secure your information. We will never initiate any email communication with you that requests your private information beyond the purposes of user identification for support. In general, we request that you do not send private information to us by email. Please contact IPlay support if you have any questions or concerns.

Children’s Online Privacy Protection

The safety of children is important to us. IPlay’s websites are for a general audience that is not directed to children under the age of 18. Similarly, IPlay’s services are not directed to or intended for anyone under the age of 18. IPlay will not knowingly accept members who are under the age of 18 years nor will it knowingly collect or maintain personally identifiable information from or about anyone under the age of 18 years. IPlay relies on the truthfulness of the registration when accepting new Members. In the event that IPlay receives information that establishes that a Member is under the age of 18 years, IPlay reserves the right, but not the obligation, to terminate that Member’s membership or take other steps that it determines are appropriate in the circumstances, such as providing parental notification. IPlay may also delete all information in our databases about that terminated Member.

Employee Access, Training, and Expectations

Our corporate values, ethical standards, and practices are committed to the appropriate protection of customer and visitor information. In general, our business practices limit employee access to confidential information, and limit the use and disclosure of such information to authorized persons, processes, and transactions. This obligation continues once an employee has left our company.

What About Other Websites Linked to Our Website?

We are not responsible for the practices employed by websites linked to or from our Sites or accessed through our Applications, nor the information or content contained in any search results or third-party websites. Often links to other websites are provided solely as pointers to information on topics that may be of interest to the users of our Sites and Applications. Please remember that when you use a link to go from a Site to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on one of our Sites, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

Your Consent

By using any of our Sites or Applications, you consent to our collection and use of your personal information as described in this Privacy Policy.

Modification of Privacy Policy by IPlay

IPlay reserves the right to change or update this Privacy Policy at any time by posting a notice that we are changing this Privacy Policy. If there is a change to this Privacy Policy, we will post the change on the Site or with the Application to keep you aware of what information we collect, how we use it, and under what circumstances we may disclose it. You will be deemed to have accepted such change if you continue to use the Site or Application after the new policy has been posted. In the event that this document conflicts in any way with the User Agreement, the User Agreement shall take precedence over the relationship.