Last Updated: June 02, 2020
Please read this Privacy Notice and Policy (“Policy”) carefully. It applies to all information DGN Games LLC and its affiliated entities (collectively “Company”, “we”, or “us”) collect from you through our web sites and game applications (collectively “Services”). Company is a developer and distributor of digital games via applications available on the Facebook platform, and via the app stores of Google, Apple, and Amazon.
This Policy describes:
• the information we collect, how we collect it, and why;
• how we use and share that information;
• how you can access and update that information;
• the choices you can make about how we collect, use, and share your information; and
• how we protect information.
If you have any questions or complaints about this Policy or Company’s use or processing of your Personal information, you can contact us as follows:
Company’s European Union (EU) Privacy Representative:
Alternatively, VeraSafe can be contacted:
In the Czech Republic:
Matthew Joseph Zahradníčkova
1220/20A Prague 15000
In the Republic of Ireland:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P Ireland
Company’s Non-EU Privacy Representative: GDPR@dgngames.com
DGN Games LLC
P.O. Box 92166
Austin, TX, 78709-2166
If you are located in the EU, you have the right to file a complaint against Us through
If you do not want us to collect, use, or share your information in the ways described in this Policy, you should not access or use the Services. By accessing or using the Services, you expressly acknowledge and agree to the terms of this Policy, and agree to the processing of your Personal Information as specified herein.
By using the Services, you acknowledge that we will use your information in the United States, and any other country where we operate. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to these countries to which we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information continues to enjoy appropriate protections. Please read on to learn more about how we protect personal information, including when we transfer personal information outside of the EU.
1. What is Personal Information?
“Personal Information” means information that specifically identifies an individual such as a name, address, telephone number, mobile number, or e-mail address, or information about an individual that could be directly linked to such identifying information such as device IP address and geo-location information (“Device Information”). Personal Information does not include “Usage Information” (meaning anonymous site usage information such as visit statistics, page views, device type, etc.), unless such information is connected to your Personal Information.
Under the EU’s General Data Protection Regulation (GDPR), to the extent applicable, personal data is defined as: “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
Information You Provide To Us.
You may choose to provide Personal Information through the Services. The Company may collect Personal Information when you request information from us, contact us, or submit comments. If you do not want your Personal Information collected in this manner, please do not submit it.
You may also elect to participate in certain activities on our Services that let you publicly communicate or share information such as player profiles, message boards, chat or messaging features, or gifting/invitation-sending features. If you participate in these activities, we may collect any or all of the information you submit, even if submitted through a player-to-player messaging system.
We will also collect your Personal Information when you access the Services through a social networking site, such as Facebook, or through Facebook Connect functionality, including any or all of the following information: your name; your profile picture; your social network ID number; your friends’ public profile data on the social networking site; your email address; your location; your gender; your birthday or age; and any other information that the social networking site chooses to share with us. If you access the public areas of the Services through a social networking site or application, we may post your profile information and picture as allowed by the social networking site.
Information Collected by Automated Means.
Whenever you use the Services, the Company, as well as any third-party advertisers and/or service providers, may automatically collect Usage Information and Device Information. The technologies used on the Services to collect Usage Information and Device Information may include, without limitation, web beacons and cookies. Web beacons (also known as Internet tags, pixel tags, tracking beacons and clear GIFs) are clear/transparent graphic images placed on a web page or email which gather Usage Information and Device Information. Cookies are data files placed on a device when it is used to visit the Services. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features on our Services may not work properly because we may not be able to recognize you, and offers we provide may not be as relevant to you.
We use tracking technologies to recognize your logged-in state on Services, to understand what Service features visitors are interested in, to make the Services function for you, and to help your browsing experience and use of the Services feel more customized. More generally, we use tracking technologies for the following.
Some cookie and similar technology functions are necessary and vital to ensuring that the Services work properly for visitors, such as maintaining the security, safety, and integrity of the Services, authentication and logging into Services (including remembering permissions and consents you have granted), and ensuring the ability to securely complete transactions.
Some technologies are used to remember your account and preferences over time, such as remembering your account or keeping yourself logged in when returning to the Services, and maintaining your choices with respect to Service features, and customizing content based on how you use the Services.
Some technologies help provide performance data on how the Services are functioning in order to improve the Services, including, for example, data on site and app functionality and speed to help us optimize the Services, and detect and gather reports on bugs to help make the Services work better.
The Services also employ Google Analytics to help us understand how the Services are used by visitors. For some of the advertising features listed below, like retargeting, data from Google Analytics may be combined with our first-party data and third-party cookies (like Google’s advertising cookies). To see how to opt-out of Google Analytics Advertising Features, see the Opt-Out section of this policy.
We partner with third-party service providers that may use various tracking technologies to permit us and them to learn about what ads you see and click when you visit the Services, or to show you ads on and off Services. These may include things such as:
Frequency capping, which limits the number of times a user’s browser or mobile device displays the same ad;
Attribution tracking, which estimates what advertising or marketing source brought someone to the Services, or determines what marketing source led to actions like a visit or a purchase;
Remarketing, which shows relevant ads to an audience based on prior browsing patterns on Services;
Audience targeting, which refers to targeting advertisements to a large audience based on the audience’s known or inferred demographics; and
Cross-device recognition, which recognizes actions across multiple devices or browsers.
Some third-party service providers may provide information like demographics, cross-device information, or interest categories from a combination of sources that, while not identifying you personally, permit us to provide you with more relevant and useful advertising. In some cases, this information may have non-marketing performance analytics uses as well.
These technologies allow a partner to recognize your computer or mobile device each time you visit the Services based on data like a cookie, your IP address, or device ID, but do not allow access to other personal information from us. However, these technologies may allow us or a third party to recognize you, either from a single device or across devices, over time. These third parties are required to follow applicable laws, self-regulatory programs, and our data protection rules where applicable. However, we do not have control over these third parties, who each have their own privacy policies and privacy practices.
Information We Receive from Third Parties.
We also may supplement and combine the information we collect about you through the Services with other information we receive from third parties in order to enhance our ability to serve you, to tailor our content to you, and to market products and services to you. In those cases, we will apply this Policy to any Personal Information received, unless we have disclosed otherwise.
When you access or use the Services, we collect, use, share, and otherwise process your Personal Information as described in this Policy. We will use Personal Information and other information we collect through the Services:
• to provide the services and information you request;
• to process your transactions through the Services;
• to contact you about your use of the Services;
• to respond to your emails, questions, comments, and complaints, and to otherwise provide customer service;
• to personalize and improve the Services, and to deliver advertisements, content, or features that match our users’ interests;
• to monitor and analyze Usage Information and otherwise measure the effectiveness of the Services;
• to send you confirmations, updates, security alerts, and support and administrative messages, to detect and prevent fraud, and to otherwise facilitate your use of, and our administration and operation of, the Services; and
• to notify you about important changes to our Services.
We rely on a number of legal bases to use your information in these ways. These legal bases include where:
• necessary to perform the contractual obligations in our Terms of Service;
• necessary in order to provide the Services to you;
• you have consented to the processing, which you can revoke at any time;
• necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
• necessary for the purposes of our or a third party’s legitimate interests, such as those of other visitors or our vendors;
• you have made the information public;
• necessary in the public interest; and
• necessary to protect your vital interests, or those of others.
4. What Personal Information do we share with third parties?
We will not share the Personal Information we collect from you through the Services with third parties, except as described in this Policy or in the Services. We may share non-Personal Information, such as Usage Information, with third parties. We may share your information with third parties in the following circumstances:
Third Parties Providing Services on Our Behalf.
We may share your Personal Information with third parties that perform services on our behalf
(or on behalf of our partners), such as companies that host or operate our Services; provide customer service; manage payments; and provide marketing services to us. Such third parties are obligated to maintain the confidentiality of your Personal Information, and only use it to provide services on our behalf as directed by us.
Your Agreement to Have Your Personal Information Shared.
We may transfer and disclose information, including your Personal Information, to third parties to comply with any legal obligation; at the request of governmental authorities conducting an investigation or otherwise requiring disclosure (including without limitation to meet law enforcement requirements and for the purposes of national security); to verify or enforce our Terms of Service; or to otherwise protect the rights, property, safety, or security of us, the public and/or other users of our Services.
The amount of time we will retain your Personal Information depends on why we collected it and how we use it. We will never retain your Personal Information for longer than we are allowed under applicable law, and otherwise, will not generally retain your Personal Information for longer than is necessary to accomplish our business purposes and protect our legal rights.
At any point while we are in possession of or processing your Personal Information, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organization.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that we refuse any of your above-specified requests, we will provide you with a reason as to why. You have the right to complain as outlined in this Policy.
All of the above requests will be forwarded on should there be a third party involved in the processing of your Personal Information.
Accessing, Updating, and Transferring Your Information.
If you want to review, change, or transfer the information we maintain about you or have additional questions, e-mail us at email@example.com. We will respond to your request within ten (10) days. Depending on the nature and scope of your request, we may require that you confirm y our identity by providing two of the following documents: birth certificate, passport, driving license, or utility bill showing name and address.
To manage the information, we receive about you from a social networking site, like Facebook, where you access or use our Services, you will need to follow the instructions at that site for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here.
Stopping Use of Your Information.
If you no longer want us to make active use of your information, you may send an e-mail to firstname.lastname@example.org request in deletion of your information. We will respond to your request within ten (10) days. Please note that certain records (for example those relating to customer service matters) will be maintained for legal and accounting purposes. Please also note that we may not be able delete all content you have posted through the Services (for example, in public forums), and we may not be able to delete all residual copies of information in our backup systems.
You may opt out of receiving marketing communications from us by sending us an e-mail at email@example.com, or by following the unsubscribe instructions in the communication that you receive. our opt-out request will be processed within ten (10) days of the date we receive it. Note that if you opt-out of marketing communications, we may still e-mail or communicate with you if we need to provide you with information about the Services, your transactions with the Services, or for any other legitimate non-marketing purposes.
Most internet browsers allow you to disable or delete cookies and reject placement of new cookies. Please be aware that certain portions of the Services may not work properly for you, or provide personalized or customized content, if you take these steps.
You can opt out of some third-party advertising programs that use your information. To do so, please visit the NAI Opt-Out Page: http://www.networkadvertising.org/managing/opt_out.asp. In order to opt-out of sharing your geolocation and other data with us from your mobile device, you can visit the “settings” page of your mobile device and review the information sharing permissions of each application or “app.”
We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (also referred to as “interest-based advertising”) and respects the DAA’s consumer choice tool for you to opt out of interest-based advertising at https://optout.aboutads.info.
If you do not wish to have your information used for the purpose of serving you interest-based advertisements, you may decline to receive interest based ads through
TrustE/TrustArc’s preferences manager (or if you are located in the EU click here). Please note this does not stop you from being served advertisements. You will continue to receive generic advertisements.
For Google Analytics Advertising Features, you can opt-out through Google Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI's consumer optout listed above). Google also provides a Google Analytics opt-out plug-in for the web.
When you install our apps on your mobile device you may receive push notifications from us, which are messages an app sends you on your mobile device even when the app is not active.
You can turn off push notifications by visiting your mobile device’s “settings” page.
When you have opted-in to receiving SMS messages (i.e. text messages) from us as provided in our Terms of Service, you can opt out of receiving the SMS messages by texting back STOP to the number we send the text from for that particular SMS message program. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.
If you access Services through our mobile applications, you may also control interest-based advertising on an iOS or Android device by selecting the “Limit Ad Tracking” option in the privacy section of the Settings App on iOS or via advertising preferences on Android-based devices (usually in the Google Settings app). This will not prevent you from seeing advertisements, but will limit the use of device advertising identifiers to personalize ads based on your interests.
If you are a California resident and you decide that you do not want us to share your Personal Information with third parties for their marketing purposes, please send an e-mail to firstname.lastname@example.org. In this e-mail, state that you would like the Company not to share your Personal Information with third parties for their marketing purposes. Your opt-out request will be processed within thirty (30) days of the date of which we receive it.
Some web browsers incorporate a "Do Not Track" feature that signals to web sites that you visit that you do not want to have your online activity tracked. Please note that Company does not interpret or respond to "Do Not Track" signals.
The Services may provide links to other web sites that we do not own or operate. We do not control, recommend, or endorse, and are not responsible for, these websites or their content, products, services, or privacy practices.
We maintain certain administrative and technical safeguards to help protect against loss, or unauthorized access to or disclosure, of your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. We cannot ensure or warrant the security of any information you transmit to us, and your use of the Services is at your own risk.
The Services are operated in the United States and other countries outside of the EU. Please be aware that information we collect will be transferred to and processed in the United State and other countries outside of the EU. By using the Services, providing us with any information, or opting in to this Policy by means of any mechanism we provide, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other territories in which the privacy laws may not be equivalent to those in the country where you reside and/or are a citizen.
We store information about players and visitors to our Services on servers located in the United States and other countries outside of the EU. Personal Information collected within the EU may be transferred to, and stored at, a destination outside of the EU. The data we hold may also be processed by employees operating outside of the EU who work for us or one of our affiliated entities or vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
To the extent that we are deemed to transfer Personal Information outside of the EU, we rely separately, alternatively, and independently on the following legal bases to transfer your information:
The European Commission has adopted standard contractual clauses (also known as Model
Clauses), which provide safeguards for personal information that is transferred outside of Europe. We often use these Model Clauses when transferring personal information outside of Europe.
We provide voluntary Services; you can choose whether or not you want to use the Services. However, if you want to use the Services, you need to agree to our Terms of Service, which set out the contract between us and our Service users. As we operate in countries worldwide (including in the US) and use technical infrastructure in the US to deliver the Services to you, in accordance with the contract between us, we need to transfer your personal information to the US and to other jurisdictions as necessary to provide the Services.
DGN complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S.
In compliance with the Privacy Shield Principles, DGN commits to resolve complaints about our collection or use of your Personal Information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact DGN at:
DGN Games LLC
P.O. Box 92166
Austin, TX, 78709-2166
DGN has further committed to refer unresolved Privacy Shield complaints to VeraSafe, an alternative dispute resolution provider located in the EU. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.verasafe.com/privacyservices/contactarticle27representative for more information or to file a complaint. The services of VeraSafe are provided at no cost to you. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
DGN is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
1. In cases of onward transfer to third parties of Personal Data received pursuant to the EU-
U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, DGN games is potentially liable.
2. DGN Games shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless DGN Games proves that it is not responsible for the event giving rise to the damage.
3. In the context of an onward transfer DGN Games has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. DGN Games shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage
The Services are not directed to children under 18. We do not knowingly collect information from anyone under 18 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information.
This Policy may be updated periodically and without prior notice to you, and any changes will be effective immediately upon the posting of the revised Policy through the Services. However, we will use your Personal Information in a manner consistent with the Policy in effect at the time the information was collected, unless you consent to its use in accordance with a new or different version of the Policy. We will always indicate at the top of this Policy when it was most recently updated.
14. How to Contact Us
If you have any questions or comments about this Policy, please contact us at email@example.com