EMPIRE GAMES LTD
Last Updated: January 4, 2022
Empire Games Ltd (“Empire Games,” “Company,” “we,” or “us”) values your privacy. Our mobile applications offer skill-based mobile games which may include the opportunity to participate in tournaments.
In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about users of our website, www.empiregames.studio (the “Site”), our mobile applications (each an “App” and collectively the “Apps”), and the services available through our Site and App (collectively, the Site, the Apps and the services available therein are the “Services”). By using or downloading an App, or otherwise using the Services, you agree that your information will be handled as described in this Policy. Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, located at http://www.empiregames.studio/terms.html, incorporated by reference herein, including its applicable limitations on damages and the resolution of disputes.
COLLECTION OF INFORMATION
We collect information directly from you, from non-affiliated entities, and by automated means as set out below. The type of information that we collect from you depends on your particular interaction with our Services, but generally includes the below information.
INFORMATION WE COLLECT FROM YOU OR IS PROVIDED TO US BY YOU
Account and Registration
Users may access most features of our Services without creating an account. However, in order to cash out winnings from our apps, users must register an account with us. The personal information we collect from you includes your first and last name, email, username (if you replace our randomly-generated username automatically assigned to your account upon its registration), password, date of birth to confirm you are old enough to use the Services, payment information for cash match games and tournament entry fees (i.e. your name and email associated with your payment account), and profile picture, should you replace our automatically-assigned Empire Games avatar. We may also ask you or allow you to submit certain optional information, which may include your updated usernames, preferences, and other profile information.
Identification Verification
We may collect certain personal information, such as first name, last name, shipping address, phone number, and Social Security number, to verify your identity when you deposit or withdraw cash from your account, to monitor for fraudulent activity, to verify that you can legally participate in cash games and withdraw funds, and to comply with legal requirements of the IRS where applicable.
Prizes and Payments
We collect information to process prize winnings, administer payments, comply with the law (including requiring W9 or W-8BEN tax forms when necessary), and maintain records of winnings and payments, which may include your PayPal email, full name, mailing address, Social Security or Taxpayer ID number, and other information necessary to complete a 1099-MISC tax reporting form, other relevant tax documentation, and physical prize fulfillment. Our Services may offer you the ability to log in to your PayPal, Skrill, or other payment method to make purchases on our platform, and we use 3rd party processors to process your payments—we do not have access to your payment card data.
Feedback
We collect and maintain records of customer service and other communications with users including survey responses, questions or comments sent to us (including the nature of the nature of the request, name and contact information), resumes provided, or other similar activities. This information may be used to enhance the Services, to provide you support in using the Services, to market to you or others, and to allow us to make appropriate hiring decisions, if submitted for that purpose.
Usage Data
We automatically collect information about your use of our Services through cookies, local storage, analytics tools and other technologies, such as your mobile device ID, IP address, location information, device name and model, operating system type, name and version, the length of time that you are using our Services and your activities within our Services (“Usage Data”) in order to operate the Services, prevent fraud, and verify you are permitted to use the Services in your location. We may combine Usage Data with other information that we have collected about you. Please see the section “Analytics and Tracking” below for more information.
Interactions and Activities
The Services allow users to play interactive games. We collect information about your activities in the Services, such as games played, scores, game outcomes, and rankings. We collect your geolocation information for purposes of verifying that you are in state, province, or country where our Services are offered.
USE OF INFORMATION
We use your information, including your personal information, for the following purposes:
Providing and Improving Our Services
To provide and maintain our Services; to provide troubleshooting; to improve our Services; to develop new features, products, or services; to perform technical operations, such as updating software; and for other customer service and support purposes.
Marketing and Communications
To communicate with you about your account and use of our Services via email and push notifications, including to send you product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes about us or our related or affiliated entities.
Research and Analytics
To better understand how users access and use our Services, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop additional products, services and features.
Protecting Rights and Interests
To protect the safety, rights, property, or security of Empire Games, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our Terms of Use.
Legal Compliance
To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
General Business Operations
Where appropriate for the administration of our general business, accounting, recordkeeping and legal functions. As part of our routine business administration, such as employee training, compliance auditing and similar internal activities.
DISCLOSURE OF INFORMATION
In general, we may share your information, including personal information, as follows:
Users
User scores, achievements and games results, as well as username and profile pictures and other user activity within the Services may be viewable by other users, such as participation in tournaments. Users may also choose to share a game on their personal social media accounts. If you participate in one of our cash tournaments, we and/or our affiliate entities may publicly display your username and tournament records.
Affiliates
We may disclose the information we collect from you to our parent, affiliate or subsidiary companies; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
Service Providers
We may disclose the information we collect from you to service providers who perform functions on our behalf.
Business Transfers
We may disclose your information to another entity in connection with an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer, including during negotiations related to such transactions.
Protecting Rights and Interests
We may disclose your information to protect the safety, rights, property, or security of Empire Games, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which we, in our sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or Terms of Use.
Legal Compliance
We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
Aggregate and De-Identified Information
We may share aggregate or de-identified information about users with third parties for research, compliance, or other purposes.
Analytics and Tracking
To ensure that our Services are being used properly—for example, being used in approved jurisdictions—we and our third-party service providers use cookies, local storage objects and other tracking mechanisms designed for mobile apps to track information about your use of our Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
COOKIES
Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through the Services for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others allow us to track your activities in our Services.
Local Storage Objects
We use local storage objects to collect and automatically store information to the local / cached data repository on your mobile device regarding your use of our Services and your preferences, which we use to enhance your experience on our Services.
Do-Not-Track
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Third Party Analytics
We may use non-affiliated analytics companies, for example Dive Analytics, to evaluate use of our Services. We use these tools to help us understand use of, and to improve, our Services, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.
EUROPEAN AND CALIFORNIA USERS
If you are a citizen of the European Union (“EU”), you may have some or all of the following rights with respect to our processing of your personal data:
Updating Your Information
If you would like to update personal information that you have provided to us, please open an App and update your profile information within the App. The changes will apply automatically to any other App with which you are already registered.
Marketing Communications
You can opt-out of receiving marketing communications from Empire Games by clicking “unsubscribe” in any marketing email communications we send you, or by sending an email to support@empiregames.studio If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.
Additional Rights for the EEA and Certain Other Territories
If you reside in certain territories (such as the European Economic Area), you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with the GDPR. We may need to retain certain information for record-keeping purposes, legal purposes, and/or to complete transactions that you began prior to requesting any deletion. You can contact our Data Privacy and Protection office by sending an email to legal@empiregames.studio.
Right Not to Provide Consent or to Withdraw Consent
We may seek to rely on your consent in order to process certain personal information and to render the Services. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
Right of Access
You may have the right to access the personal information that we hold about you.
Right of Erasure
In certain circumstances, you may have the right to the erasure of personal information that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).
Right to Object to Processing
You may have the right to request that Empire Games stop processing your personal information and/or to stop sending you marketing communications.
Right to Correct
You may have the right to require us to correct any inaccurate or incomplete personal information. You may easily do so within the Services app.
Right to Restrict Processing
You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held).
If you would like to exercise any of the above rights, please contact legal@empiregames.studio so that we may consider your request under applicable law. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
California Privacy Rights
California Civil Code section 1798.83 requires us to disclose to our California customers, upon request, the identity of any third parties to whom we have disclosed Personal Information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes. Please note that under California law, we are only required to respond to a customer request once during any calendar year.
If you are a California resident and would like to make either type of request described above, please contact us at legal@empiregames.studio.
Should you desire to exercise one or more of these rights, please contact us using the contact details at the end of this Policy. You also have the right to lodge a complaint to your local data protection authority at: https://edpb.europa.eu/about-edpb/board/members_en.
WE CANNOT VERIFY THE IDENTITY OF NON-ACCOUNT HOLDERS
Please note that if you have not registered an account with us through the Services, we do not have a reasonable means to verify your identity for a privacy-related request regarding your personal data due to the limited information we collect from non-registered account holders. The following categories of information are what we could potentially passively collect from non-registered account holders, although we do not necessarily keep/store all of the following data:
Device information obtained in the performance of the Services:
Device type (e.g. Pixel XL or Samsung 10S)
Device operating system (e.g. iOS or Android)
Device operating system version (e.g. 7.1.2)
Device language (e.g. English)
Device IP address (e.g. 12.345.678.901)
Device user agent (e.g. HTTP header that transmits the above information)
Device time zone
Device location to ensure the Services are being accessed in allowed jurisdictions:
Internet protocol position
Connection to affiliate or referral identification
Game statistics:
Match scores, account transactions as they pertain to our virtual currency and the outcome of the match (i.e. deduct or add to your balance based on win or loss)
Other information you might provide to us:
Conversations with support, either in-App or via e-mail
THIRD-PARTY LINKS
Our Services may contain links to third-party websites or applications. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
SECURITY OF INFORMATION
We have implemented safeguards to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared device.
RETENTION
We will retain personal information we collect from you where we have a justifiable business need to do so and/or for as long as is needed to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (such as tax, legal, accounting or other purposes). You can request deletion of your personal information at any time (see above) and we will consider your request in accordance with applicable laws.
When we have no justifiable business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
YOUR CHOICES
We may send periodic informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.
CHILDREN
Our Services are for a general audience and are not designed for children under 18, and we do not intentionally collect information on our Services from those we actually know are under 18. If we discover that a child under 18 has provided us with personal information, we will delete such information from our systems.
CHANGES TO THIS POLICY
Each time you use our Services, the current version of the Privacy Policy applies. This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as via email or prominent notice within the Services.
CONTACT US
If you have questions or concerns about the privacy aspects of our Services, or would like to make a complaint, please contact us at support@empiregames.studio.
To see our Terms of Service, visit this page: http://www.empiregames.studio/terms.html.