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Privacy Policy

Athena FZE provides this Privacy Policy to explain how it collects, stores, and uses the information collected in connection with Athena FZE’s software applications, and websites (collectively, “services”). Athena FZE respects the privacy of their users and is committed to protecting the user’s information. You have a right to know our practices regarding the information we may collect and use when you use our services.

This privacy policy is effective as of November 1, 2019.

The types of information we collect and how we collect it

Personal Information

Athena FZE collects the advertising identifier (Apple’s IDFA and Google’s advertiser ID), and a unique identifier for each user in our mobile games.

Athena FZE integrates many third party SDKs in to our services. These SDKs are used for advertising to our users, analyze service usage, enabling in-app purchases, or providing game services like achievements and leaderboards. We allow third party operators this collected solely for internal operations of the service as permitted by applicable rules and laws. This could include, but is not limited to, persistent advertising identifiers, geolocation information, and IP address. We encourage you to review the policies of the third party operators listed below.

Should a user explicitly provide it to us when prompted, we will collect email addresses of our users for our mailing list(s).

Some of our services require or allow a user to provide a screen name so they can be identified within the service.

Non-personal Information

We allow third parties to collect some anonymous information by which users cannot be identified. Non-personal information may include technical information about your device, such as your browser type, screen resolution, device type, language, type of operating system and geo location (only general location). Non-personal information is gathered by third party services while you are accessing the service. They are allowed to use this information to conduct research and analysis, but only for strictly limited purposes. We encourage you to review the policies of the third party operators listed below.

Internally, Athena FZE also reserves the right to collect anonymous information for research and analysis. This information is generic in nature and cannot be used to individually identify a user. This information is collected each time a user runs one of our services.

Service Specific Information

Some Athena FZE services allow users to send messages to each other while playing a game. These messages are then transmitted and store on Athena FZE controlled servers.

In order to support some services, Athena FZE may collect identifiers associated with a user’s account on social networks like Facebook or Twitter, or game services like Apple Game Center, Google Play Game Services, or Amazon Game Circle.

Additionally, we may also use a user’s profile picture from social networks or game services, but this will stay on the device and will not be transmitted to us.

What we do with the personal information we collect

Advertisers collect data regarding advertisement performance, user’s interaction with ads, our apps and user’s interests. Collected data may include user’s personal information in order to serve users ads and for the third parties’ legitimate business interests.

Athena FZE collects persistent identifiers in order to provide support for our services to our users. Additionally, Athena FZE uses persistent identifiers to send promotions regarding new products or updates to our users. If we keep track of persistent advertising identifiers, it allows us to only notify these users about new products that they will actually be interested in. We collect email addresses in many of our services so that we can notify interested users of upcoming releases and updates of our products and services. These emails always include a way to unsubscribe from receiving future emails. When a service asks for a username, it is used to visually identify that user to other users playing the game. Athena FZE prohibits any user under the age of 13 from providing individually identifiable information in their username or screen name. This includes, but is not limited to the user’s first name, last name, email address, and physical address.

What we do with the non-personal information we collect

Third party operators are allowed to collect and use non-personal information to conduct research and analysis, or to target advertisements, or other limited purposes. This information cannot be user to individually identify any user. We encourage you to review the policies of the third party operators listed below.

Similarly, Athena FZE also uses non-personal information to conduct research and analysis. We do this to improve our services in future updates or to gain knowledge about how our users our interacting with the service.

What we do with service specific information we collect

Each of our games that allow messaging other users provide an option for joining or creating publicly visible worlds/matches, or for playing only against other users known to the current user. Athena FZE prohibits any user under the age of 13 from joining or creating publicly visible worlds/matches in these services. Additionally, Athena FZE prohibits any user under the age of 13 from sharing personal or individually identifiable information while using the messaging functionality in these services.

If Athena FZE collects identifiers associated with a user’s account on social networks like Facebook or Twitter, or game services like Apple Game Center, Google Play Game Services, or Amazon Game Circle, then it is explicitly required for some feature in that service. For example, the identifier could be saved so that a user’s connections on the social network can see their high score or progress in the game. As stated elsewhere in this policy, you can contact us to have this information deleted for yourself or your child under the age of 13.

Children

We understand the importance of protecting the privacy and safety of children using our services, as outlined by the Children’s Online Privacy Protection Act of 1998 (COPPA). Accordingly, we do not knowingly collect, use, or disclose personal information from children under 13.

When we determine that a service is directed and children under the age of 13, we will configure all of our internal systems such that no personal information will be collected, and configure all relevant third-party integrations appropriately such that no personal information will be collected for users of that service. For additional information, please refer to the privacy policies of our third party operators to understand what they are doing to further protect your child’s privacy.

Services that are determined to be targeted at children will still receive advertisements from our third-party operators, and promotions from Athena FZE using its internal systems. In this case the ads and promotions will not be targeted at specifically for users, but will be broadcast to all users of the service.

If you are a parent of a child under 13 years of age and you believe your child has provided us with personal information, please contact us using the information below and we will delete the information from our systems.

Disclosure of Personal information

The scenarios in which we will share your personal data are as follows:
We determine that it is required by law;
We have a good faith belief it is necessary to protect our rights or property;
We are participating in a merger, acquisition, liquidation, dissolution or sale of assets;
We have your consent; and
As described above in relation third-party operators collecting information from our services.
Under no other circumstances will Athena FZE share, sell, rent, or release your data.

Security

We follow generally accepted industry standards and internal procedures to protect personal information submitted to us, both during transmission and once we receive it.

Third-party Operators

Advertising Networks: Athena FZE allows advertisements from the Third Party ad networks to be displayed in our services. Athena FZE makes commercially reasonable efforts to ensure that the third party ad networks are configured to comply with applicable privacy laws, and we reasonably believe this to be the case for each of them. Additionally, if we determine a service to be directed at children under the age of 13, we configure each of these ad networks to be compliant with the Children’s Online Privacy Protection Act of 1998 (COPPA).

In-App Purchases: In order to make an in-app purchases, a user must use a third party checkout options that we have integrated with our services to finalize and pay for their order. The third party operator’s privacy policy and security practices will apply to this process a user’s information. We encourage you to read that privacy statement before providing your information.

Social Networks: Some of our services integrate a third-party social network such as Facebook or Twitter to allow sharing progress with friends, or allowing them to be invited to use our service. The privacy policy of each social network will indicate what data is available to us and how we use it.

Game Services: Many of our services integrate either Apple Game Center, Google Play Game Services, or Amazon Game Circle. Each of these third-party operators offer their own privacy policy (listed below), and we encourage you to review them.

The following is a list of the third party operators we currently use in our services, their contact information, and links to their privacy policies:

Apple, iAd, Game Center http:// www.apple.com/ legal/ privacy/ en-ww/ contact/
http:// www.apple.com/ privacy/ privacy-policy/
AdColony
Attn: Privacy Officer
11400 W. Olympic Blvd., 12th Floor
Los Angeles, CA 90064
[email protected]
http:// www.adcolony.com/ privacy-policy/
AppLovin Corporation
849 High St.
Palo Alto, CA 94301
[email protected]
https:// www.applovin.com/ privacy
Chartboost
420 Taylor Street
San Francisco, California 94102
[email protected]
https:// answers.chartboost.com/ hc/en-us/articles/ 200780269-Privacy-Policy
Facebook, Inc.
1601 Willow Road
Menlo Park, CA 94025
https:// www.facebook.com/help/ contact/861937627253138
https:// www.facebook.com/ policy.php
Flurry
Yahoo! Inc.
Customer Care – Privacy Policy Issues
701 First Avenue
Sunnyvale, CA 94089
[email protected]
https:// policies.yahoo.com/ us/en/yahoo/ privacy/index.htm
Google Play, AdMob, Google Play Game Services, Google Anayltics, Firebase Analytics
https:// support.google.com/policies/ troubleshooter/2990837?hl=en
https:// play.google.com/about/ play-terms.html
https:// www.google.com/intl/en/ policies/privacy/
UnityAds
Unity Technologies
795 Folsom Street
San Francisco, California 94107
[email protected]
https://unity3d.com/ legal/privacy-policy
Vungle
185 Clara Street,
San Francisco, CA 94107
[email protected]
http://vungle.com/privacy/
Appsflyer
100 1st Street, 25th floor,
San Francisco, California 94105
[email protected]
https://www.appsflyer.com/ privacy-policy/
Changes to this Privacy Policy
We will periodically update this privacy policy to reflect changes in our information practices, and to add additional third party operators. Please check back regularly, as your continued use of our services indicate your acceptance of any changes to this policy.
Privacy Policy Contact Information
If you have any questions about our privacy policy, please contact us via email at [email protected]