This privacy policy describes how we, Sidra Tech (“Sidra Tech”), collect, use, disclose and otherwise process personal information in connection with our games (“Games”) and websites or other online interactions outside of Games (“Websites”) (“Games” and “Websites” collectively referred to herein as “Services”). Please read this privacy policy carefully so that you understand our information practices. Unless applicable laws require us to obtain your consent in a different way, you consent to us processing your personal information in the ways and for the purposes described in this privacy policy by downloading and/or playing our Games or accessing our Websites.

Please read this privacy policy carefully. We may update it from time to time by posting a new version here. If we make any material changes to our practices, we will notify you through our Services.

The information we may collect falls into three categories: (1) information collected directly from you; (2) information collected automatically from your device, and (3) information collected from third parties.

(1) information we collect directly from you

Games: When you download or play one of our Games, we may collect:

- Registration information, including a name, username or other identifier, and password.

- Information on your activity in our Games , such as your game progress or your interactions with in-game ads. Your gameplay records are stored in the cloud if you opt in to Cloud Save in certain Games. In other Games, your gameplay records are stored locally on your device if the Apple & Google Play platforms support that feature.

- If you purchase physical goods from us, we collect purchase information, such as quantity and type of goods purchased, name of purchaser, and shipping address.

- If you pay for virtual currency or other virtual items in our Games, we collect information about the transaction, including your ZIP code or postal code, information regarding your existing virtual items in our Games and the items you paid for, the amount of the transaction, and records of payments you have made. Additional information about these transactions is provided in the “Virtual Items” section below.

- Marketing preferences, such as records of your requests to opt out of marketing communications.

(2) information we collect automatically

- We use in-app analytical tools to collect unique user ID, IP address, device IDs, hardware or operating system based identifiers, identifiers we assign to your account, and other similar identifiers (collected from your device).

- Your general geographic location (for example, country, state, or city), determined based on your IP address.

(3) information we collect from third parties

- Sidra Tech may collect user information through the third-party advertising networks on Games. This information may include your device ID, a unique advertising ID associated with your device, and your approximate geographic location. For more information, see the “Advertising” subsection below.

- If you use a third-party platform to connect with Games, we collect third-party platform account information based on the information you make available on that service (such as your name, profile picture, age range, gender, and your friends). Please keep in mind that when you post information on a third-party site or platform, that site or platform independently determines how to use your information. The information Sidra Tech collects is covered by this privacy policy but the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our Games.

Sidra Tech may use your information for the following purposes depending on how you interact with our Services:

- To provide you with the products and services you request, including to provide our Games.

- To operate, administer, and troubleshoot our Services.

- To analyze usage patterns and performance of our Games.

- To fulfill your orders.

- To advertise to you, as described in the “Advertising” subsection below.

- To provide you with customer support.

- To send you newsletters or product updates by email if you have subscribed to our newsletter.

- To send you notifications about real-time updates, transactional messages, and reminders.

Sidra Tech may also combine information that we collect from you with information we obtain about you from third parties. We may aggregate and/or de-identify any information collected through our Services. We may use de-identified and/or aggregated data for any purpose permitted by applicable law, including without limitation for research and marketing purposes, and may also disclose such data to any third parties.

We may disclose your information in the following circumstances:

- When we contract with a third party to provide services to us, including to develop and maintain our Games. These parties provide a variety of services, including, without limitation, order processing, billing, sales, marketing, advertising, market research, fulfillment, data storage, analysis and processing, and legal services.

- To third parties in connection with the sale, merger, or reorganization of all or part of the Sidra Tech business.

- To enforce our Terms of Use or rules, to ensure the safety and security of our users and third parties, to protect our rights and property and the rights and property of our users and third parties, address issues relating to security or fraud, to comply with legal process or in other cases if we believe in good faith that disclosure is required by law.

- At your direction or with your express consent, such as if you direct us to disclose your information to third-party sites or platforms, such as social networking sites, or when you write a review that you expressly permit us to publish on our Services.

- As described in the “Analytics and Advertising” section below.

Please note that once we disclose your information to another organization in any of the circumstances set out above, the information received by the other organization becomes subject to the organization’s own privacy practices. However, when companies perform services on our behalf as service providers, like customer service, we have agreements with those companies that govern their data practices and prohibit them from using your information for purposes other than those requested by us or required by law.

We have Games for everyone (“Everyone Games”), as well as more complex games that are only intended for users that are 13 and older (“Complex Games”). Complex Games require strategic thinking and problem solving and may have mature content.

Sidra Tech collects data on users under the age of 13 only when necessary:

- To deliver the game and access network features.

- To serve contextual advertising, as noted above.

- To provide you with the products and services you request.

Sidra Tech may use this data for the following purposes because these purposes are in Sidra Tech’s legitimate business interests:

- To maintain and analyze game functioning.

- To detect, investigate and prevent actions to ensure legal and regulatory compliance.

- To protect the security and integrity of our users and Sidra Tech Games.

For Everyone Games, we work only with selected ad networks that respect the tag-for-child-directed (TFCD) parameter—aka the ‘COPPA flag’—on a per-app or per-request basis, so that interest-based advertising is switched off, and personal information collection is restricted. In addition, these ad networks are able to categorize and tag their ad creatives by age, so that the ads are appropriate content-wise.

If you are a parent or legal guardian of a child under the age of 13 who uses the Games, please contact us at [email protected], if you have any questions or comments. If you are a parent or guardian, you may review the information we have collected from your child or ask us to make no further use of, or delete, such information. We may need to verify your identity before implementing your request.

We have taken steps to implement technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use and modification. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

Pursuant to our contract with you to provide you with our Services, your information will be processed on servers that may not be located where you live, including on our servers hosted in the United States and other locations where we or our vendors or technology providers are located. The laws of these countries may not be as protective as the laws in your country, and in some circumstances, we may be required to disclose your information to law enforcement or intelligence authorities. Users outside the United States should be advised that by using our Services, you acknowledge and, unless applicable laws require us to obtain your consent in a different way, you consent to that transfer. No matter where our servers are located, we handle your information in accordance with this privacy policy.

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. If we make any material changes to this privacy policy, we will post the updated privacy policy here and notify our users as required by law. Please check this page frequently to see any updates or changes to this privacy policy.

The Services may contain links to other sites or apps not owned or controlled by us and we are not responsible for the privacy practices of those sites or apps. We encourage you to be aware when you leave our Services and to read the privacy policies of other sites or apps to which our Services may link.

If you have questions about this privacy policy, please contact Sidra Tech at [email protected].