Last Updated: February 21, 2023

This Privacy Policy (the “Policy”) explains how your personal data is collected, stored, and processed by Alerion Media LLC ("Alerion Media", “we”, “us”, or “our”) when you use or access our software or website, collectively herein referred to as the “Service”.

Privacy is important, so we take our responsibility of caring for your data seriously. In order to provide a high quality experience, we process some information from and about you to improve the Service and to support internal operations.

Please note that the scope of this Policy is limited to information collected or received by Alerion Media through your use of the Service. Alerion Media is not responsible for the actions of any third parties, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to third party content does not constitute our sponsorship of, or affiliation with, those people or companies.

1 Data We Collect

Generally, “Personal Information” is information that relates to an identified natural person or could be reasonably linked so as to identify a natural person. We endeavor to only collect information that is relevant to our legitimate business purposes or for lawful purposes of processing. The information we collect comes from a variety of sources when you interact with us and the Service.

In some instances, information is collected in the aggregate that does not relate to any natural person or household (“Aggregate Data”), such as the number of Service users per day. In other instances, personal information can be sufficiently anonymized that it cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular user (“Anonymous Data”). You acknowledge and agree that Alerion Media may process your personal information to render such information Anonymous Data, and to process your personal information in combination with other information to render it Aggregate Data. 

1.1 Data Collected Automatically

When you use the Service, some information may be collected automatically including:

  • Device information: OS version, model, manufacturer, time zone, IP address, language

  • Device identifiers: IDFA, Game Center ID, Google Play ID, Ads IDs, Device IDs

  • Usage information: interactions with the Service, save data, progress, achievements

  • Consumption information: purchase history, usage data

  • Cookies and similar technologies: preferences, activity

  • Log information: past actions, Service performance history

1.2 Data You Provide

Depending on how you choose to interact with us or the Service, and whether you contact us for support, some additional information may be collected including:

  • Contact information: email address, name, phone number

  • Profile information: virtual name, photo, statistics, settings, username, password

  • Message history: any messages you send to us or transmit via the Service

1.3 Data We Collect From Our Partners

We may leverage some third-party partners such as social networking sites, data analytics providers, and advertiser networks as part of the Service, and they may provide us with additional information including:

  • Demographics: age, birth date, gender, interests

  • Payment verification: purchase confirmation data

  • Advertising: history of interactions and preferences regarding advertisements 

  • Analytics: usage metrics regarding third-party services

  • Fraud prevention: history of hacking, cheating, or attempting to gain free virtual goods or currencies

  • Provided data: additional data you explicitly provided to third-parties

2 Why Do We Collect Your Data

Our primary objective in collecting such information is to provide and enhance the Service, and to enable you to easily navigate and enjoy the Service. We use such information for a variety of business purposes, such as:

2.1 To Make The Service Work

  • Create or track accounts that allow you to interact with the Service

  • Operate the Service

  • Verify and confirm payments

  • Provide and deliver products and features you request

  • Communicate with you regarding the Service

2.2 To Improve The Service Over Time

  • Optimize the Service

  • Manage our relationship with you

  • Provide social features

  • Customize your experience

  • Respond to your comments, questions, and provide support

  • Communicate with you regarding information related to the Service

2.3 To Show Personalized Advertisements

  • Track content you access in connection with the Service and your online behavior

  • Deliver, target, and improve our advertising and the Service

Note that you may opt-out from personalized advertisements at any time in the privacy settings of your device.

2.4 To Analyze, Profile, And Segment

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

2.5 With Your Consent

Under applicable privacy laws, including the General Data Protection Regulation (GDPR), you must first provide consent in order for us to process your data in certain ways. With your consent, we may process your data for additional purposes such as displaying and personalizing ads. With your consent, this data may also be shared with selected partners for such ad delivery and personalization. The partners operate the ad network and mediation platform, as well as facilitate and participate in ad inventory bidding. The partners may also use such data for fraud detection purposes based on their legitimate interest.

3 Who Can See Your Data

Other than Alerion Media, your Personal Information can be shared with others in the following ways:

3.1 Other Users Of The Service

Social features may allow other users of the Service to see your profile data and a subset of your interactions and activity with the Service.

3.2 Our Third-Party Service Providers

In situations where we work with a vendor, they may process your data as needed to perform tasks on our behalf such as providing support, advertising, summarizing analytics, and creating dashboards.

3.3 Other Companies And Authorities

We may share your data with third party payment companies in order to verify your payments, and to help combat fraud and illegal activity. We may also provide your data to authorities or law enforcement in response to their lawful requests. We may also share your data based on your consent, to protect rights, property, or personal safety.

3.4 Advertising And Social Media Partners

While using the Service, you may encounter features offered by our partners such as social media interaction tools or in-app advertising. These partners may access your data for purposes of delivering targeted advertisements to you. They operate under their own privacy policies, so we encourage you to review their privacy policies to learn more about their data processing practices.

4 Data Retention

We will retain your personal information for as long as is necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law, for legal, tax, or regulatory reasons, or for other legitimate and lawful business purposes.

5 How Do We Protect Your Data

We do not own or directly manage any servers or databases that contain your data. Instead, we rely exclusively on third party services designed to specialize in such tasks such as Microsoft Azure, Amazon AWS, and/or Heroku. Additionally, we take reasonable security precautions to prevent your data from being accessed by unexpected or disallowed parties.

6 Where Your Data Is Stored

We rely on third parties that store and process your information only in the United States. 

7 International Transfers

Because the Service is inherently global, we may transfer your data from your country or jurisdiction to other countries or jurisdictions around the world, including the United States. If you are located in a region with laws governing data collection and/or use that differ from U.S. law, please note that you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

8 Disclosure For California Residents

The following subsections of this Section 8 apply only to residents of California.

8.1 Data Collection

The categories of personal data we have collected in the preceding 12 months, and the sources of said data, are described in the “Data We Collect” section of this Policy.

8.2 Data Use

The business or commercial purposes for collecting your personal data are described in the “Why Do We Collect Your Data” section of this Policy.

8.3 Data Disclosure And/Or Sale

We do not “sell” your personal data or exchange it directly for money. However, we may share advertising identifiers with third-party advertising platforms to deliver interest-based advertisements, attribute installs, and optimize campaign performance. To the extent that practice is considered a “sale” under the CCPA, you may opt out of said sharing by disabling targeted advertising in your device settings.

We do not have actual knowledge of any sale of personal data of minors under 16 years of age, as the term “sale” is defined under the CCPA.

In the preceding 12 months, we have disclosed the following categories of personal data as part of our Services:

Category of Personal Data Collected: Identifiers

Examples of Data Collected: A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers

Categories Of Third Parties Who May Receive Personal Data For A Business Purpose: Other Players (username and profile only), Service Providers, Business Partners, Advertising Networks (Advertising identifier and IP address only)

Category of Personal Data Collected: Personal data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Examples of Data Collected: A name, telephone number

Categories Of Third Parties Who May Receive Personal Data For A Business Purpose: Service Providers

Category of Personal Data Collected: Protected classification characteristics under California or federal law

Examples of Data Collected: Age, gender, language

Categories Of Third Parties Who May Receive Personal Data For A Business Purpose: Service Providers Advertising Networks (for compliance purposes only)

Category of Personal Data Collected: Commercial information

Examples of Data Collected: Records of products or services purchased, obtained, or considered, or other purchasing or consuming history or tendencies

Categories Of Third Parties Who May Receive Personal Data For A Business Purpose: Service Providers, Advertising Networks

Category of Personal Data Collected: Internet or other electronic network activity

Examples of Data Collected: Browsing history, information on a consumer’s interaction with an internet website, application, or advertisement

Categories Of Third Parties Who May Receive Personal Data For A Business Purpose: Service Providers, Advertising Networks

Category of Personal Data Collected: Inferences drawn from other personal data to create a profile about a consumer.

Examples of Data Collected: Profile reflecting a consumer's preferences, characteristics and behavior.

Categories Of Third Parties Who May Receive Personal Data For A Business Purpose: Service Providers

9 Your Rights

We provide you with choice and control over our use of your information, including your ability to exercise your data privacy rights.

9.1 Options Via Settings

Certain processing of your information can be disabled simply by changing settings on your device.

  • The Service may attempt to schedule local notifications or send you push notifications. You may opt out at any time from receiving these notifications by changing the notification settings on your device.

  • The Service may request a personalized advertisement. You may opt out at any time in the privacy settings of your device.

9.2 Other Options

You have the right to correct your data, have your data deleted, restrict how we use or share your data, object to how we use or share your data, and withdraw your consent. If you wish to exercise any of these data protection rights, please contact us per the contact information in this Policy. We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not satisfactorily addressed, you may contact your local data protection authority.

9.3 Right To Equal Services And Prices

We will not discriminate against you for exercising any of your CCPA rights, such as:

  • Denying you access to the Service

  • Charging you different prices for the Service

  • Providing you a different level of quality of the Service

10 Modifications

Alerion Media reserves the right, at its sole discretion, to change, modify, add, or remove portions of this Policy by posting the amended Policy on the Service. We will notify you by revising the date at the top of the Policy. Your use of the Service after changes to the Policy are posted will be subject to the updated Policy and constitutes your acceptance of any changes. If at any point you do not agree to any portion of the then-current version of the Terms of Service or Privacy Policy, or any other Alerion Media policy, rules, or codes of conduct relating to your use of the Service, your right to use the Service shall immediately terminate and you must immediately stop using the Service.

11 How To Contact Us

If you have questions about the Alerion Media Privacy Policy or would like to exercise specific rights regarding your data, send an email to alerion+privacy@alerionmedia.com.