Game Circus Privacy Policy

Effective Date: May 24, 2024

Your privacy is important to Game Circus Studios, LLC (“Game Circus”). This Game Circus Privacy Policy (“Privacy Policy”) describes how Game Circus may collect, use, store, disclose, and process your personal information, when you use our Services (as defined below). Please read it before using Game Circus’ Services because it tells you how we collect, store, use, disclose, and otherwise process your personal information when providing these Services to you. This Privacy Policy is not, however, a contract and does not create any legal rights or obligations.

Game Circus may change this Privacy Policy from time to time by posting changes at this URL and may send notification emails. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes.

If you have questions, comments, or concerns regarding our Privacy Policy or practices, please Contact Us in accordance with section 13, below.

1.  Introduction

Game Circus develops and publishes social games for mobile devices. Our Privacy Policy applies whenever you use our “Services”, which means our games, brands, products, Services, content, www.gamecircus.com, and/or other domains or websites operated by Game Circus. This Privacy Policy applies whenever you use our Services. It describes how we collect, store, use, disclose, and otherwise process your personal information when providing these Services to you, and your rights and choices concerning your information.

“Game Circus,” “we,” “our,” or “us” in this Privacy Policy refers to Game Circus Studios, LLC and any other parent, subsidiary or corporate entities under common ownership with Game Circus Studios, LLC (“Affiliated Entities”).

For purposes of data protection laws, Game Circus Studios, LLC  is the “data controller” of your personal information, and the Data Processor list can be found at www.gamecircus.com/third-parties.

We refer to countries in the European Union (EU) and the European Economic Area (EEA), the United Kingdom (UK) and Switzerland collectively as the “European Countries” in this Privacy Policy.

By using these Services, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services or play Game Circus’ games.

2.  Information We Collect and How We Collect It

a.  Information About You That You Share With Us Directly

When you use our Services, you may give us information directly, and we will store that information on our systems and use it for the purposes described in this Privacy Policy. For example:

• your first and last name;
• your e-mail address; and/or
• other information that helps us to identify you or helps us to provide or improve our services.

If you give us your mobile telephone number (including for SMS text messaging services), we will also collect and store that number.

 b.  Information You Generate Using Our Services

When you use our Services, we collect information about the ways in which you use and interact with our Services, such as:

• when and for how long you play our games;
• game features;
• other players you interact with;
• purchases you make;
• progress or levels you achieve, and
• other gameplay activities.

We may collect information to:

• protect the safety and well-being of our players;
• to protect Game Circus’ rights and property in connection with our Services;
• to conduct research;
• to operate, improve, personalize, and optimize our Services and our players’ experiences, including through the use of analytics; and
• to manage and deliver advertising.

Where required by law, we will seek your consent for this.

c. Payment Information

When you play Game Circus’ games or access any of our other Services on connected third-party applications or platforms (e.g., Apple, or Google), any purchases you make (such as in-game virtual currency or items) will be processed by that third- party application and subject to that third-party application’s terms of service and privacy policy. For these purchases, Game Circus does not receive your financial information, but may receive non-financial information related to your purchases, like your name, username, approximate physical location, amount paid and the items purchased. The information Game Circus receives depends on the Game Circus game you’re playing and the third-party application. Game Circus’ Terms of Service explain our policies and terms related to your use of our Services, charges, billing, third-party credits, and virtual currencies. Please note that purchases of third-party credits or currencies are also subject to those parties’ terms of service and privacy policies. You can find our Terms of Service at: www.gamecircus.com/termsofservice.

d.  Customer Support Correspondence

When you ask for help from our Customer Support team (including via Contact Us, section 13, below), we will collect and store:

• the contact information you provide (generally, your name and e-mail address);
• information about your game play or activity on our Services, and
• the communications you have with our Customer Service team and any additional information in those communications in order to provide support and improve the Services.

e.  Information About You That We Get From Connected Third-Party Applications, Including Social Networks

If you play Game Circus’ games and through them connect our Services to any third-party applications, such as Google Play Game Services, iOS Game Center or social networks like Facebook, Game Circus may receive certain information about you from the provider of the third-party application. The information we receive depends on the Game Circus game you’re playing, the third-party application, your privacy settings, and, if applicable, your friends’ privacy settings on that third-party application.

For example, Game Circus may collect and store some or all of the following information from the provider of the connected third-party application:

• your first and last name;
• your profile picture or its URL;
• your user identification number (like your Facebook ID number), which may be linked to publicly available information like your name and profile photo;
• your friends’ user ID numbers and other public data;
• the e-mail address you provided to that third-party application;
• your approximate physical location and that of the devices you use to access our Services;
• your gender;
• your birthday, age, and/or age range;
• information about your activities on or through the connected third-party application;
• other publicly available information on the third-party application; and/or
• any other information that you or the provider of the third-party application share with Game Circus.

If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s terms of service and privacy policy.

If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

f.  Cookies and Other Automated Information Collection

We may use cookies, log files, web beacons, pixel tags, clear gifs, device identifiers, advertising identifiers and similar tracking technologies, including those from third-party service providers like Google Analytics, Google Tag Manager, HubSpot, and other cloud-based tools, to automatically collect your preferences, performance data, and information about your web usage when you visit the Services.

• Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, count visits, and understand how users interact with ads.
• Web beacons are electronic images that may be used in our Services and help deliver cookies, count visits, and understand usage and campaign effectiveness.

You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or mobile devices, but such adjustments may affect or disable certain functionality of the Services. You can learn more about Google Analytics and your options for opting out of interest-based Google ads at https://adssettings.google.com. You can learn more about targeted ads and your ability to opt out of receiving interest-based ads at optout.aboutads.info and www.networkadvertising.org/choices.

We, our service providers, and our business partners use these cookies and other similar technologies to collect and analyze certain kinds of technical information, including:

• IP address;
• platform type (like Apple iOS or Android);
• your operating system version;
• your mobile device’s identifiers, like your Apple Identifier for Advertising (IDFA), and/or Android Advertising ID (AAID);
• application performance and de-bugging information;
• your browser type and language;
• referring and exit pages, and URLs;
• the number of clicks on an app feature or web page;
• the amount of time spent on an app feature or web page;
• domain names;
• landing pages;
• pages viewed and the order of those pages; and/or
• game state and the date and time of activity on our Services.

If you play Game Circus games on a mobile device, in addition to your device identifiers (described above), we may also collect:

• the name you have associated with your device;
• your general location (city, country);
• your telephone number (if you provide it);
• your specific geolocation (with your permission);
• information about the Game Circus games and other third-party apps you have on your device.

If you want to adjust your privacy preferences on your device, please see Section 5, below (Your Rights and How to Access, Update, and Manage Your Personal Information).

g. Taxpayer Information

We may require players (US Citizens and Residents) to complete an online US IRS Form W-9 (Request for Taxpayer Information) if a player wins a prize in one of our online Sweepstakes. For complete rules and Sweepstakes Eligibility, please read COIN DOZER SWEEPSTAKES OFFICIAL RULES.  WINNERS ARE SOLELY RESPONSIBLE FOR ALL FEDERAL, STATE, PROVINCIAL, AND LOCAL TAXES ASSOCIATED WITH THE RECEIPT OR USE OF ANY PRIZE.  The US IRS W-9 will be used by Game Circus to generate, mail, and file US IRS Form 1099-MISC to both the player and the US Internal Revenue Service. Please note that it is a crime for US Citizens and Residents to provide false, incorrect, or misleading information on an IRS Form W-9.

h.  Other Sources

We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.

3.  How We Use Information We Collect and Our Legal Bases for Processing It

We use your information under several legal bases, including to establish and perform our contract with you, for our legitimate interests, to comply with our legal obligations, to establish, use and protect Game Circus’ rights, or otherwise with your consent.

The main use of the information we collect and store is to provide you with the Services you request from us and to improve your gaming experience, but there are other uses as well. The uses for which we collect and store your information include:

• to improve and optimize our Services and our players’ experiences;
• to create your game accounts and allow you to play our games;
• to identify and suggest connections with other Game Circus players and personalize our Services to you;
• to communicate with you about the Services you’re using, including in-game updates, new Services, and promotional offers that we think might be of interest to you;
• to save and associate your activity across our Services and your different devices as well as associate any accounts you may use across Game Circus Services together. We may associate activity and accounts under a single user ID;
• to create analytics and reports for external parties, including partners, publishers, advertisers, apps, third parties and the public regarding the use of and trends within our Services and ads, including showing trends to partners regarding general preferences, the effectiveness of ads, and information on user experiences;
• to enable players to communicate with each other;
• to provide technical support and respond to player inquiries;
• to protect the safety and well-being of our players;
• to protect Game Circus’ rights and property in connection with our Services;
• to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
• to manage and deliver contextual and behavioral advertising;
• to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners.
• to comply with our legal obligations; for example, If you win one of our sweepstakes, you may be required to fill out a US IRS W-9 (Request for Taxpayer Information) so we can send you a US IRS 1099-MISC and correctly report winnings to the Internal Revenue Service;
• to resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and/or
• to conduct research.

If you are located in the European Countries (as defined above in Section 1), our legal basis for collecting and using the information described above depends on what the information is and the context in which we collect it.

However, we’ll normally collect information from you only where we need it to perform our contract with you (i.e., our Terms of Service), where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights), or if we otherwise have your consent.

If we ask you to provide information to comply with a legal requirement or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your information, and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing information is mandatory.

Similarly, if we collect and use your information in reliance on legitimate interests (or those of any third party) which are not listed above, it will be made clear to you at the relevant time what those legitimate interests are (such as personalizing our services and marketing, for example).

If you have questions or need further information about the legal bases on which we collect and use your personal information, please Contact Us in accordance with section 13 below.

4.  How We Share Information

We do not share, sell (as the term is defined under applicable privacy laws, such as the California Consumer Privacy Act), or disclose your personal information other than with categories of third parties in the following circumstances:

a.  Friends and Other Game Circus Players

Game Circus’ games and Services support and may encourage you to interact with other players. In most Game Circus games, if you play through a social network or connect to a social network (for example, Facebook), your social network friends who also play a Game Circus game may see your name, photo, player (which may include the information described above in subsection 2a (Information About You That You Share With Us Directly)), and descriptions of your in-game activity (including any Game Circus games you have played).

b.  With Our Group Companies

We may share your personal information within the Game Circus Affiliated Entities to enable the Game Circus Affiliated Entities to carry out the purposes set out in this Privacy Policy.

c.  Third-Party Advertising Including Behavioral Advertising and Analytics

We use advertising to enable us to offer some of our games, game features, and other Services for free. These advertisements may include, without limitation, banner ads on Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer to provide virtual currency or other in-game items to players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, completing a survey, or finishing a particular game level. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Game Circus.

We do not actively share personal information that directly identifies you with third-party advertisers for their direct marketing purposes unless you give us your consent.

To enable advertisers, ad networks, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:

• performance data (like the number of clicks on an advertisement);
• certain technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
• a unique identifier, such as your social network ID; and/or
• other contextual data about your game play (like your level and session length).

In addition to serving you with relevant ads, the information collected may be used to:

• measure how effective ads are;
• offer you targeted advertising (both on and off our Services) in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as interest-based advertising or behavioral advertising); and/or
• undertake web analytics to analyze traffic and other player activity to improve your experience.

Advertisers or ad networks may collect this information through the use of cookies and other similar tracking technologies, and they may use a single tracking technology or multiple tracking technologies at the same time.

Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Game Circus.

For a full list of our partners, including those to show you interest-based ads, please visit www.gamecircus.com/third-parties.

If you do not want to receive tailored in-application advertisements from third parties, please see Section 5 below (Your Rights and How to Access, Update, and Manage Your Personal Information). For more information on controlling the use of cookies and similar technologies, please see subsection 2f above (Cookies and Other Automated Information Collection). Please note that the practices of third-party companies delivering advertisements on our Services are subject to those companies’ own privacy policies.

d.  Safety, Security, and Compliance with Law

Your information, and the contents of all of your online communications in our Services and between you and Game Circus may be accessed and monitored as needed to provide our Service and may be disclosed:

• to satisfy any laws or regulations that apply;
• when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
• when we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
• to protect the rights or property of Game Circus or applicable third parties, including to enforce our Terms of Service.

e.  Third-Party Service Providers

We will share your information with third-party companies who perform services on our behalf, like payment processing, analytics, analysis, hosting services, customer service, marketing, and advertising optimization. We will also share your information with our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple, Google, Facebook, Amazon, etc.). Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information (as required by applicable data protection laws).

For a full list of our partners, please visit www.gamecircus.com/third-parties.

f.  Sale or Merger

In the event that Game Circus undergoes or evaluates undergoing a business transition, like a merger, acquisition by another company, or sale of all or part of its assets (like selling a game), we may disclose or transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to let you and other players know (in the way described in Section 12 below (Changes to Our Privacy Policy)) of any such business transitions when they occur.

g.  Other Third Parties

In addition to the sharing described above, we may share your information with other third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy if we have your consent to do so.

5.  Your Rights and How to Access, Update, and Manage Your Personal Information

b.  Accessing, Updating and Deleting Personal Information Held by Game Circus

There are several ways that you can access, update or delete your data:

• In most cases, you can easily delete your data at any time by deleting the app and/or resetting your Advertiser ID. We can no longer associate any stored data with you.
• If you have linked a social account (e.g., Facebook, Google Play Game Service, or Apple GameCenter), then you can unlink the app with those social providers to disassociate yourself with any stored data. If you do this, your unique username and gameplay may no longer be retrievable.
• If we have collected and processed your personal information with your consent, then you can change your consent at any time.
  • On mobile devices: you should be able to do this via the “Settings” menu in your Game Circus game app. From the Settings menu, choose “My Data” and change your existing consent settings
• If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device’s “settings” page. Many of our games also offer the ability to turn off push notifications in the in-game “settings” page.
• Most web browsers are set to accept cookies by default. If you prefer, you can change the settings on your browser to remove or reject cookies; however, the Services may not function properly if you do so.
• If you want to review or delete personal information associated with your game account data, or if you have any further questions regarding the removal of data please submit a request to our Data Protection Officer at privacy@gamecircus.com or Contact Us in accordance with section 13 below.

For deletion requests, we will take reasonable measures to delete your personal information from our records. If you have sent content through or posted content on the Service, we may not be able to delete it. We will keep certain records (e.g., personal information relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We’ll also keep information in order to exercise, defend, or establish our rights.

c.  Managing Personal Information We Receive From Third-Party Applications / Platforms And From Your Mobile Device

To manage the information Game Circus receives about you from a third-party application or platform where you play our games, like Apple, or Google, you will need to follow the third-party application’s instructions for updating your information and changing your privacy settings.

You also can manage many aspects of information collection and use from your mobile device by visiting the “settings” page of your mobile device and reviewing the access permissions of each Game Circus game / application.

Most of our mobile games utilize a Google-certified consent management service, Didomi, which allows you to manage the data you share with us; these options are based on where you live and are intended to ensure we comply with the local privacy legislation applicable to you.  Where you have given consent, you may review and update personal data consent by visiting the “settings” page in that game, and using the ‘My Data’ button.

Once Game Circus receives your information from a third-party application / platform or your mobile device, that information is stored and used by Game Circus in accordance with this Privacy Policy. You may access and update that information as described above.

d.  Opting Out of Promotional Communications from Game Circus

If you want to stop receiving promotional e-mails from Game Circus, click on the “unsubscribe” link at the bottom of any promotional email from Game Circus. Your unsubscribe request will be processed promptly, and in no event longer than ten business days. During that processing period, you may receive additional promotional emails from us.

If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device’s “settings” page. Many of our games also offer the ability to turn off push notifications in the in-game “settings” page.

Please note that if you opt out of receiving promotional communications from us, we may still communicate with you from time to time if we need to provide you with information about the Services you are using from us, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non- marketing reasons, for example, if we are required under applicable laws to notify you of updates to this Privacy Policy or our Terms of Service.

e.  Opting Out of Third-Party Behavioral Advertising

If you do not want to receive behavioral in-application advertisements from third parties that relate to your interests on your mobile device, you may adjust the ad tracking settings.  Your mobile device may provide you with the ability to limit this functionality, which is based on a unique advertising ID.

Apple: Apple requires apps to ask permission before they can access your advertising ID.  When you install a new app, it should ask you for permission to track you.

• Tap “Ask App Not to Track” to deny it your permission, or
• Tap “Allow” if you want to share your data.

To see which apps you have previously granted access to:

• Go to “Settings > Privacy > Tracking”.
• Here you can disable tracking for individual apps that have previously received permission. Only apps that have permission to track you will be able to access your advertising ID.
• You can set the “Allow apps to Request to Track” switch to the “off” position (the slider is to the left and the background is gray). This will prevent apps from asking to track in the future. If you have granted apps permission to track you in the past, this will prompt you to ask those apps to stop tracking as well. You also have the option to grant or revoke tracking access on a per-app basis.

Apple has its own targeted advertising system, separate from the third-party tracking it enables with the advertising ID. To disable it:

• Navigate to “Settings > Privacy > Apple Advertising” and set the “Personalized Ads” switch to the “off” position to disable Apple’s ad targeting.

Android: Devices using Android 12 or higher can delete their advertising ID permanently. The steps to do this will vary based on the device manufacturer, and you may need to consult your device user manual (or manufacturer website), but the steps on most devices will be similar to this:

• Go to “Settings” and navigate to “Privacy > Ads”.
• Tap “Delete advertising ID,” then tap it again on the next page to confirm. This will prevent any app on your phone from accessing it in the future.
• On some devices, you may find ‘Privacy” under “Security and Privacy” or “Other Privacy Settings”.
• On older versions of Android, open “Settings > Privacy > Advanced > Ads”, and turn on “Opt out of Ads Personalization” and confirm your changes.

Please note that if you opt out of certain Interest Based Advertising, you may continue to receive contextual ads based on other non-personal information, such as ads related to the content of the game you are using.

If you are interested in more information about behavioral advertising and your choices to prevent behavioral web and mobile web advertising from third parties, you may visit the following websites:

• Network Advertising Initiative Consumer Opt-Out Pageor the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising; and
• Your Online Choiceswebsite for EU-based advertising.

Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for behavioral advertising.

All of the opt-out tools described in this subsection are provided by third parties, not by Game Circus. Game Circus does not control or operate these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive third-party advertisements in Game Circus’ Services after using these opt- out tools, but the advertising you see may be less relevant to your interests.

f. Exercising Your Rights

We will not unlawfully discriminate against you for exercising your rights under applicable privacy law. To make a privacy request, please Contact Us in accordance with section 13 below.  We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as your email or account information, such as email address/ device type/ device ID where applicable, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

g.  European Countries’ Users’ Rights

If you are located in the European Countries (defined above in Section 1), you have the following data protection rights:

• You can access or request deletion of your personal information by submitting a request to our Data Protection Officer at privacy@gamecircus.com.
• You can correct or update your personal information, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• You can opt-out of marketing communications we send you by following the instructions in “Opting Out of Promotional Communications from Game Circus” below.
• If we have collected and processed your personal information with your consent, then you can update your consent at any time.
  • On mobile devices: you should be able to do this via the “Settings” menu in your Game Circus game app. From the Settings menu, choose “My Data” and change your existing consent settings
• Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority (Contact details are available )

To exercise your rights to access or deletion, please submit a request to our Data Protection Officer at privacy@gamecircus.com. If you have any problems or would like to exercise any of your other rights, you can Contact Us in accordance with section 13 below. We respond to all data protection requests we receive in accordance with applicable data protection laws.

h.  California Notice and Privacy Rights

k.  Users in the Republic of Turkey

If you are located in the Republic of Turkey, you have the rights listed under Article 11 of the 6698 No. Law on Protection of Personal Data.  These are addressed elsewhere in this Privacy Policy, including:

• As detailed in Section 2 of this Privacy Policy – information sources and how we collect it;
• As detailed in Section 3 – for what purposes we use information we collect;
• As detailed in Section 4 – with whom we share information; and
• In this section 5 – how to access, update, change or withdraw consent and manage your personal information, including certain provisions of CCPA which may also apply to your Country’s privacy laws where appropriate.

If you have specific questions that are not addressed herein to your satisfaction, you can Contact Us in accordance with section 13 below.

l.  Residents of Brazil

7.  Privacy Policies of Linked Third-Party Services and Advertisers

Our websites and games may contain advertisements from “Third-Party Services,” meaning companies other than Game Circus, which may link to their own websites, online services, or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.

8.  Our Policies Concerning Children

Generally speaking, most of our Services are not intended for children under the age of 13 (or under 16 for children located in the European Countries) (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.

Though our Services do not target Children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as Children in our age-gate on such Services, if we allow Children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA, or obtain legally valid parental consent.

If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that information from our records.

If you believe that your child may have provided us with personal information, please contact our Data Protection Officer at privacy@gamecircus.com

9.  International Operations and Transfers Out of European Countries

As part of our international operations, we may transfer personal information to our “Affiliated Entities,” which are any other corporate entities under common ownership with Game Circus Studios, LLC , or to our business partners and service providers from time to time for our legitimate business purposes.

We store personal information about players and visitors to our sites on servers located in the United States, and we may also process this information in other countries where our Affiliated Entities, business partners and service providers have their operations. Personal information collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries for purposes such as: (i) the processing of transactions and your payment details, or (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, 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.

EU and UK residents should direct any questions, concerns or complaints regarding Game Circus’ handling of personal information to Game Circus at:

GAME CIRCUS STUDIOS, LLC
ATTN: Data Protection Officer
1600 Rio Grande Street
Austin, TX 78701
privacy@gamecircus.com

We will attempt to answer your questions and satisfy your concerns in a timely and complete manner.

You may exercise any rights you have to correct, amend, or delete information about you as described in Section 5 above (Your Rights and How to Access, Update, and Manage Your Personal Information).

10.  How Long We Keep Your Information

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you use our Services, and/or have contacted us (for example, Customer Service). We will take reasonable measures to delete this personal information if you stop using our Services. However, you acknowledge that we may retain some information where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

11.  Security of Your Information

We implement reasonable and appropriate security measures to help protect the security of your information both online and offline and to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information.

When you sign into your Game Circus account or enter payment information, we and our third-party payment processor use encryption to transmit that information.

While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please Contact Us in accordance with section 13 below.

12.  Changes to Our Privacy Policy

If we decide to make material changes to our Privacy Policy, we will tell you and other players by placing a notice in- game or on www.gamecircus.com. We may supplement this process by placing notices on game blogs, social network pages, and/or player forums. You should periodically check www.gamecircus.com and this Privacy Policy for updates.

13.  Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or privacy practices, you can send an e-mail to the Data Protection Officer at privacy@gamecircus.com. For all other matters, please contact Game Circus at support@gamecircus.com  or write to us

GAME CIRCUS STUDIOS, LLC ,
Attn: Customer Support
1600 Rio Grande Street,
Austin, TX 78701.