Privacy Policy

This policy explains what information we collect when you play our games, why we collect it, who we share it with, and what you can do about it.

Contents

1. Who we are and how to reach us
2. Who and what this policy covers
3. Information we collect
4. Notice at collection
5. Why we use it, and our legal basis
6. Advertising and your choices about it
7. Who we share information with
8. Your US state privacy choices
9. Where your information goes
10. How long we keep it
11. How we protect it
12. Deleting your account
13. Your rights, and how to use them
14. Children and young people
15. Automated decisions and profiling
16. Region-specific information
17. Changes to this policy
18. Contact

1. Who we are and how to reach us

Offsuit Games, Inc. is the controller of the personal information described in this policy. We are a corporation organized under the laws of the State of Delaware, United States.

Our Privacy Officer handles privacy questions and requests.

If you are in the European Economic Area or the United Kingdom, Section 16 says which data protection authority covers you and how to reach it.

2. Who and what this policy covers

This policy applies to every Offsuit Games, Inc. game, application, and website that links to it, and to the servers and services behind them.

Not every game has every feature. Where a section of this policy describes a feature, it applies only to those of our games that offer it, and features described here may not be available in every game or in every country.

One account across our current games. All the games we offer today share a single user account and a single user record. Your profile, balances, unlocks, and purchase history are the same in every one of them, and information you provide in one is visible to the others.

Guest accounts. Some of our games create an account for you automatically the first time you open them, without asking you to sign in. We call that a guest account. Everything in this policy applies to a guest account, except that we hold no email address or sign-in identifier for it until you sign in.

This policy does not cover the practices of companies we do not own or control. Advertising networks, app stores, and sign-in providers handle information under their own policies, and they are responsible for what they do with information they collect or receive. We are not responsible for their use or protection of it. Section 7 explains the roles those companies have, and how to ask us which companies they currently are, so you can find those policies.

3. Information we collect

You do not have to give us anything. But we cannot create or run an account without a user identifier and a username, we cannot deliver a purchase without a purchase record, and we cannot sign you in without an email address or a sign-in identifier — so if you do not provide those, you cannot use the corresponding parts of our games.

3.1 Information you give us

3.2 Information created by playing

3.3 Information collected automatically from your device

3.4 Information we receive from others

3.5 Other information

Information not specifically listed above that you give us, or that your use of our games generates, which we use as this policy describes or as we tell you at the time we collect it.

3.6 Permissions, payment details, and sensitive information

We do not collect precise location. The games we offer today do not request location permission, and the only location information involved is approximate and derived from your IP address — see Section 3.3. Payment card details go to Apple or Google and never reach us — see Section 3.2.

We do not ask you for sensitive personal information, and we do not intentionally collect it. We do not seek information such as your race or ethnicity, your religion, your political opinions, your union membership, your health, or your sex life or sexual orientation. Please do not send us information of that kind — in a support message, in written feedback, or in a username.

We keep our use and disclosure of sensitive personal information inside the purposes that California law treats as exempt, so no right to limit it arises.

4. Notice at collection

This section is the notice we give you at or before the point we collect personal information. It sets out the categories we collect, what each one is used for, whether it is sold or shared, and how long we keep it.

The purposes below are the ones described in Section 5, and they carry the same meaning here.

To opt out of the sale and sharing of your personal information, see Section 8.3 or use the "Do Not Sell or Share My Personal Information" control in your game's privacy settings.

5. Why we use it, and our legal basis

The table below sets out the purposes we use personal information for. The "Legal basis" column applies if you are in the European Economic Area, the United Kingdom, or Switzerland, and identifies the basis under Article 6(1) of the GDPR.

Where we rely on legitimate interests, you may object to that processing at any time — see Section 13. We may continue only where we have compelling legitimate grounds that override your interests, or where we need the processing to establish, exercise, or defend legal claims.

Where we rely on consent, you may withdraw it at any time, and withdrawing it does not affect what we did before you withdrew it.

We may also use personal information for any other purpose we describe to you at the time we collect it, and, where the law requires your consent for a new purpose, we will ask for it first.

6. Advertising and your choices about it

This section applies to those of our games that show advertising.

We work with advertising partners who select and deliver the advertisements you see, and with a partner who measures which advertising campaign brought you to our game.

Those partners receive your advertising identifier, technical information about your device and our app, the approximate location derived from your IP address, and information about the advertisements you were shown and interacted with. Those partners use that information for their own purposes as well as ours, including to build profiles and to select advertising for you in other apps and websites.

Section 7 explains how we treat each kind, and how to ask us which companies they are.

Your choices

On Apple devices, we ask for your permission before your advertising identifier is used for tracking. If you say no, we and our partners do not receive it. You can change your answer at any time in Settings → Privacy & Security → Tracking.

On Android devices, you can delete or reset your advertising identifier, and opt out of personalized advertising, in your device's Google settings under Ads.

In the European Economic Area and the United Kingdom, we ask for your consent before any advertising or analytics partner reads an identifier from your device or uses it for personalized advertising. We use a consent management tool to collect and record that choice. If you do not consent, you will still see advertising, but it will not be personalized.

In the United States, see Section 8.

7. Who we share information with

This section explains the two roles a partner can have. You can ask us which companies they currently are by emailing info@offsuit.app.

7.1 Companies that handle information for us

These companies handle information on our behalf. We require them to use it only to provide their services to us. They provide services such as hosting and infrastructure, sign-in, crash reporting and performance monitoring, product analytics, purchase and subscription management, consent management, email delivery, content moderation, and customer support.

Between them they receive your email address and display name, your user ID, your account and profile, your game state, your purchase records, your consent records, your usage and interaction data, your crash reports and performance data, your device and app identifiers, and your IP address. Our analytics providers receive activity data linked to your user ID.

7.2 Companies that use information for their own purposes

These partners are independent controllers of the information they receive: our advertising partners, and our install attribution and advertising measurement partner. To the extent that sharing with them constitutes a "sale" or a "sharing" of personal information under US state privacy law, Section 8 explains your choices about it.

Between them they receive your advertising identifier, your installation identifier, your device and app information, the approximate location derived from your IP address, your app interaction data, your advertising activity, and crash and diagnostic data. Our measurement partner also receives your user ID and your purchase history.

Each of these partners processes the information it receives under its own privacy policy and is responsible for what it does with it. We are not responsible for their use or protection of that information.

7.3 Other sharing

• Apple and Google. Purchases and subscriptions are processed by the App Store or Google Play under their own terms. They tell us that a purchase succeeded; we do not receive your payment details.
• Sign-in providers. If you sign in through a third-party provider such as Google or Apple, that provider knows you signed in to our game and receives information from your device under its own policy.
• Other players. In games with social features, other players can see your public profile and other information about your account and your play — information such as your username, avatar, level, competition placements, subscription badge, and public profile statistics.
• The public. Where we feature a player, we may show information such as that player's username, avatar, rank, competition placements, and gameplay statistics on our websites, on our social media channels, and in advertising and promotion of our games, and anyone can then see it. Our Terms describe this. Once something is public, we cannot recall copies other people have already made.
• Legal and safety. We may disclose information where we believe in good faith that it is necessary to comply with a law, regulation, legal process, or governmental request; to enforce our Terms & Conditions; to detect, prevent, or address fraud, cheating, security, or technical issues; or to protect the rights, property, or safety of Offsuit, our players, or anyone else.
• Business transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction. Where we are able to, and where the law requires it, we will tell you.
• Professional advisers. Our lawyers, accountants, auditors, and insurers, where they need it and under a duty of confidentiality.

We may also share personal information in other ways that we describe to you at the time, where you ask or permit us to, or where we are legally required to. We may use and share information that has been anonymized or aggregated so that it no longer identifies you, for any purpose and without further notice.

8. Your US state privacy choices

This section applies to residents of US states with comprehensive consumer privacy laws. Which of the rights below you have depends on the law of the state you live in. Not every right is available to every resident, none of them is absolute, and we may decline a request where the law permits.

A note on the word "sale". US state privacy law defines "sale" and "sharing" much more broadly than everyday use: passing an advertising identifier to an advertising network so that it can select advertising may be a "sale" or a "sharing" under those definitions, even though no money changes hands for your information. We do not sell your personal information in the everyday sense, we do not sell it for money, and we have not done so in the preceding twelve months — except to the extent that the advertising described in Section 6 constitutes a "sale" or a "sharing" under those laws.

8.1 What we collect, why, and who gets it

Using the categories set out in California Civil Code § 1798.140:

We do not have actual knowledge that we have sold or shared the personal information of any consumer under 16 years of age. Our current games are for adults and we do not knowingly collect information from anyone under 18.

We disclose Categories A, B, D, F, G, and K to the service providers described in Section 7.1 for the business purposes described there.

We use and retain each category for as long as Section 10 states.

8.2 Your rights

• Know. Ask what personal information we have collected about you, the categories, the sources, the purposes, the categories of third parties we disclosed it to, and the specific pieces of information we hold.
• Delete. Ask us to delete personal information we collected from you, subject to the exceptions the law allows.
• Correct. Ask us to correct inaccurate personal information.
• Opt out of sale and sharing. Tell us to stop selling and sharing your personal information, including for cross-context behavioral advertising.
• Know who we shared it with. Where your state's law gives you the right, ask us for the third parties we disclosed or sold your personal information to.
• No retaliation. We will not deny you service, charge you a different price, or give you a lower quality of service because you exercised a privacy right.
• Appeal. Where the law of your state gives you a right to appeal a refusal, you may appeal by replying to our response or emailing info@offsuit.app with "Privacy Appeal" in the subject line.

8.3 How to opt out of sale and sharing

In the app: open the game's privacy settings and use "Do Not Sell or Share My Personal Information". You will still see advertising; it will not be personalized.

By email: write to info@offsuit.app with "Do Not Sell or Share" in the subject line and tell us your user ID, or the email address on your account. We cannot act on a request that does not give us enough to identify your account.

Opt-out preference signals. Where a browser sends a Global Privacy Control signal or another recognized opt-out preference signal to a web page we operate, we treat it as a valid request to opt out of the sale and sharing of personal information. That request applies only to the browser and device it is sent from.

Do Not Track. Some browsers can send a "Do Not Track" signal. There is no agreed standard for what a service should do when it receives one, and we currently do not respond to it. We do respond to Global Privacy Control, as described above.

Authorized agents. You may use an authorized agent to make a request. We will ask the agent for written proof, signed by you, that you authorized them, and we may ask you to verify your identity with us directly or to confirm that you gave that permission, to the extent the law allows.

8.4 How we handle requests

Send requests by email to info@offsuit.app. You can delete your account, and opt out of the sale and sharing of your personal information, in your game's privacy settings. We acknowledge and respond to requests within the time the law of your state requires, and where that law allows us to extend, we will tell you.

Before we give you information about your account, correct it, or delete it, we verify that the request is really from you, and we may confirm that you live in a state whose law gives you the right. Where we need to, we may ask you to sign in, to write to us from the email address on the account, to tell us details we can check against what we already hold, to show government identification, or to sign a declaration under penalty of perjury where the law allows one.

We do not do that for an opt-out. For an opt-out we need only enough to know which account to apply it to, which is why Section 8.3 asks for your user ID or the email address on your account.

9. Where your information goes

We are based in the United States, and your information is processed there. Our service providers and advertising partners operate globally.

If you are outside the United States, your information will be transferred to and processed in the United States, and may also be processed in other countries where we or our service providers and partners operate infrastructure. The rules that apply to personal information in those places are not always the same as the rules where you live, and are sometimes weaker.

How we protect those transfers. Where we transfer personal information out of the European Economic Area, the United Kingdom, or Switzerland, we rely on one of the mechanisms the law allows: an adequacy decision covering the destination country or the recipient; standard contractual clauses approved by the relevant authorities, together with any additional measures a transfer requires; or, in limited circumstances, an exception the law permits for a particular transfer. You may have the right to ask us for a copy of the safeguards we rely on. Email info@offsuit.app.

10. How long we keep it

We keep each kind of information for as long as the purpose we collected it for lasts. The table below gives the criteria we apply to each. Where a period is fixed by law rather than by us, we say so.

Except for the records this section says survive account deletion, nothing obliges us to hold on to information for any length of time unless the law requires it. We may delete it securely whenever we choose, for any reason or none, and we do not have to tell you first.

11. How we protect it

We maintain technical and organizational measures designed to protect personal information, including encryption where we consider it appropriate, and access controls that limit personal information to those who need it for their work.

No system is completely secure, and no transmission over the internet can be guaranteed, so we cannot promise that our measures, or those of the companies that handle information for us, will prevent every unauthorized access.

12. Deleting your account

You can delete your account at any time. In the app, open the privacy settings and choose to delete your account.

Deleting your account deletes it everywhere. Because our current games share one account, deleting it in one game deletes it in all of them, along with the balances, unlocks, and progress you had in every one.

If you have a subscription, cancel it through the store you bought it from before you delete your account — deleting your account does not stop the billing.

When you delete your account:

• your account is closed and you can no longer sign in;
• the personal information we held to run your account is deleted or de-identified, and we keep some account-related information for the purposes described below; what we delete disappears from our backups as the backup cycle completes;
• your in-game currency, items, and progress are permanently lost and cannot be restored; our Terms say what closing an account means for them; and
• if you play again later, you start over with a new account.

What we keep, and for how long. Deletion does not reach:

• purchase and transaction records — for as long as tax, accounting, and audit law requires;
• consent records — for as long as the agreement between us could still be the subject of a claim, so that we can show what was agreed;
• records of a restriction, suspension, or closure for breach of our Terms — for as long as we need them to enforce our Terms consistently;
• anything we are legally required to keep, or that we need to establish, exercise, or defend a legal claim — for as long as that purpose lasts; and
• material we have already published that features you — a post or an advertisement stays up until we take it down, and we cannot recall copies other people have already made. See Section 7.3.

You cannot undo this. Once your account is deleted you cannot sign in to it again, and we cannot restore your progress.

13. Your rights, and how to use them

Which of these rights you have depends on the law where you live. Where that law gives you one, you can use it:

• access the personal information we hold about you, and receive a copy of it;
• correct information that is wrong or out of date;
• delete your personal information, and close your account;
• export the personal information we hold about you that you provided to us or that your use of our games generated, in a format that can be read and used by automated tools;
• restrict particular uses of your information;
• object to processing we base on our legitimate interests, including profiling; and
• withdraw your consent where we rely on it, including your advertising consent.

Section 16 sets out what applies in the regions we name. These rights are not absolute. They are subject to the conditions and exceptions of the law that gives them, and where that law allows us to decline a request, or to act on only part of it, we may.

Two things do not depend on where you live.

You can delete your account at any time, from the app. Section 12 says exactly what that removes and what it does not.

You can tell us to stop using your personal information for direct marketing addressed to you at any time. Email info@offsuit.app. You will still receive service messages — things like purchase confirmations, security notices, and replies to your support requests.

How to ask. Email info@offsuit.app. Tell us what you want and give us your user ID, or the email address on your account. You can delete your account in your game's privacy settings.

What happens next. We respond within the period the law that gives you the right requires. Where a request is complex, or where you have made several, we may take longer where that law allows, and we will tell you. Normally you will not have to pay a fee. If a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse it. Where the law requires it, we will tell you why.

Verification. We may ask you to confirm your identity before we act on a request about your account, so that we do not give your information to someone else.

If you are not satisfied. Please tell us first — email info@offsuit.app with "Privacy Complaint" in the subject line. We will respond as applicable law requires. You may also complain to your data protection authority. Section 16 names the ones for the regions it covers.

14. Children and young people

Every Offsuit game available today is intended for people aged 18 and over. They are not directed to children, and we do not market them to children.

We do not knowingly collect personal information from anyone under 18 in those games, we do not knowingly sell or share the personal information of anyone under 16, and we do not target advertising at anyone we know to be a minor. We reserve the right to ask for proof of age at any point, and to restrict or close an account where we believe its holder is below the age required to use the game.

Where we learn that we hold personal information about someone under 18 who is using a game intended for adults, we may close the account and delete the information, keeping only what Section 12 requires us to keep.

If you are a parent or guardian and you believe a young person has provided us with personal information, email info@offsuit.app and we will take reasonable steps to delete it.

Where we learn that a person is under 13, we delete the personal information we collected from them.

15. Automated decisions and profiling

Profiling we do. We derive information about you from your account activity — for example, a player rank in games that have one. Section 5 sets out what we use it for.

Automated systems we use.

1. Content moderation. Text you submit may be checked for offensive material by an automated system, and rejected.
2. Fraud, cheating, and abuse detection. Automated signals help us identify accounts that appear to be cheating, making fraudulent purchases, or otherwise breaking our Terms & Conditions.

We do not use your personal information to train large language models, and we do not sell or share it with anyone else to train them.

Automated signals help us decide whether to restrict, suspend, or close an account. Our Terms say how to contest such a decision. Where the law where you live gives you a right to human review of an automated decision that significantly affects you, or a right to question the result of profiling that fed such a decision, you may ask for it and we will provide it.

We do not make decisions about you by automated means alone that produce legal effects for you or similarly significantly affect you, unless the decision is necessary for entering into or performing a contract with you, you have consented to it, or the law authorizes it.

16. Region-specific information

16.1 European Economic Area, United Kingdom, and Switzerland

The controller is Offsuit Games, Inc. (Section 1).

Your rights are those in Section 13. Under the GDPR and the UK GDPR you have all of them: access and a copy; rectification; erasure; restriction of processing; data portability; objection to processing based on our legitimate interests, including profiling; an absolute right to object to direct marketing; the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects; the right to withdraw consent; and the right to lodge a complaint with a supervisory authority.

Complaints. You may complain to the data protection authority in the EU or EEA country where you live, work, or where you believe an infringement occurred; a list is published by the European Data Protection Board at edpb.europa.eu. In the United Kingdom, you may complain to the Information Commissioner's Office at ico.org.uk. In Switzerland, you may contact the Federal Data Protection and Information Commissioner at edoeb.admin.ch.

16.2 Everywhere else

Where the law where you live gives you a privacy right this policy does not describe, that law applies to you. Email info@offsuit.app and tell us what you want.

17. Changes to this policy

We may update this policy. When we do, we will change the "Last updated" date at the top and post the new version at offsuit.app/privacy.

If we make a material change — for example if we start using your information for a new purpose, or start sharing it with a new kind of recipient — we will tell you, in the app or by another appropriate means, and where the law requires your consent we will ask for it.

For changes that do not affect your rights — corrections, clarifications, updated contact details — the updated policy takes effect when it is posted.

This policy is written in English. The English version governs. Translations are provided for convenience only, and where a translation differs from the English version, the English version prevails.

18. Contact

Email: info@offsuit.app

Mail:

Offsuit Games, Inc.
8 The Green, Suite B
Dover, Delaware 19901
United States

Privacy contact: Our Privacy Officer — info@offsuit.app

See also our Terms & Conditions.

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© Offsuit Games, Inc.