This Privacy Notice will be effective from November 1^st , 2023.

To access the previous privacy notice, click HERE .

This Privacy Notice (the “Privacy Notice” or “Notice”) is provided to help you understand our practices regarding how we collect, use, share and protect personal data. In this Privacy Notice, “Innplay Labs” refers to G.S Innplay Labs Ltd., Ha’sadnaot 8, Herzliya, Israel, the data controller, and “Playtika” refers to Playtika Ltd. (the parent company of Innplay Labs) and its subsidiaries, which shall mean subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership. We may also refer to InnplayLabs as “we” or “us”.

This Privacy Notice applies whenever you use our applications (“Apps”) or visit our websites (“Site”) and together ”Services”.

By using the Services, you agree to the collection, disclosure, storage and use of personal data as described in this Privacy Notice. If you do not want us to collect, store, use or share the personal data you provide in the ways described in this Privacy Notice, you should not use our Services.

Privacy Notice Key Points

 The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section to find out more information about any topic. These key points do not substitute the full Privacy Notice.

1. Personal Data We Collect.
2. How We Use Personal Data.
3. How We Share Personal Data.
4. International Transfer.
5. Security.
6. Your Rights.
7. Data Retention.
8. Cookies and Similar Technologies.
9. Third-Party Applications and Services.
10. Communications.
11. Children.
12. Changes to the Privacy Notice.
13. Comments and Questions.
14. Supplemental U.S. state laws notice

1. Personal Data We Collect.

We collect personal data to fulfil one or more of our functions and activities, depending on your usage, and as described in this Privacy Notice.

Under current law in most countries, the personal data we collect is generally not considered sensitive.

If you are a visitor to our Site, we may collect the following personal data about you:

Automatically Collected Data – When you visit the Site, we may automatically collect information about your device, operating system, browser type and language of browser, IP address, general information about your location (country and city), and information regarding your viewing history on our Site. We may collect such data by using cookies and similar technologies. For more information about cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.

Contact Information – When you request information from us or contact us for any other reason using the Site, we may collect any data you provide, such as your email address, your name and the content of your inquiry.

If you are a user of our mobile Apps, we may collect the following Personal Data about you:

Personal Data That You Share with Us Directly

When you use our Apps, you may give us information directly in a number of ways, including:

• to set up your account;
• in response to surveys or other research we conduct;
• to participate in contests and sweepstakes;
• in communications with customer support agents and account managers;

The information you share with us may include, for example:

• your age or birthday;
• your first and/or last name;
• your e-mail address;
• information about your account, a device on which you are playing one or more of our games and/or trying to access our Service, and/or other information about a request or inquiry you make;
• other information that helps us make sure it is you are accessing your account, including as necessary for us to provide the support you request, or information you provide to help us improve our Service (such as answers to an online survey or a feedback form).

When you use our Service, you may also have an option to create a profile that other players can see. In your profile, you may be able to include information like:

• a profile photo;
• game username(s);
• biographic details (like your age and/or gender);
• a country, state, and/or city where you live
• links to one or more social media profiles;
• details about your gameplay (like your game progression or rewards earned).

Data You Generate While Playing Our Games

When you use the Apps, you generate certain information, such as information about game sessions (including timing, number and length), progress in the game (e.g, level and achievements), items collected, collaborations, and other choices you make in the game (like the way you interact with certain features or pop-ups). Additionally, we automatically collect information about your mobile device, such as your operating system, device ID, information about your approximate location (i.e. country / state), and information regarding your purchase history on our Apps.

Personal Data We Get from Others

We may receive information about you from other sources like third-party applications, such as an app store, third party login service, and social networks on which you play our games, such as Facebook. For example, to the extent you choose to login using your Facebook account, we will have access to certain information about you through your Facebook account, namely, your Facebook profile name, email address, and list of friends. You can adjust some of the information that you decide to share from your Facebook account. We may use this information along with information you provide us directly in a number of ways as described in this Privacy Notice, for example, to help you connect and to provide you with a more personalized game experience.

If you access our Service from a third-party application or connect our Service to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Notice. 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.

We may collect and process some or all of the following information shared by the third parties:

• your first and last name;
• your profile picture or its URL;
• your user ID number (like your Facebook ID number), which may be linked to other information like your name and profile photo, and your friends’ identifiers;
• your friends list, which includes the user ID number and other information of your friends, like their names and profile photos;
• the login e-mail you provided to the third-party application;
• any other information that you or the provider of the third-party application share with us;

We may also obtain basic information about purchases made through a third-party platform or store (for example, Facebook, Apple, or Google).

2. How We Use Personal Data.

We may use personal data for a variety of business purposes as described in this Privacy Notice and based on several legal bases, including your consent, the performance of a contract with you, complying with legal obligations, and other legitimate interests, such as to:

• create game accounts and allow gameplay;
• operate, improve, and optimize our Service and our players’ experiences, including by measuring interest, personalize the game through segmentation and engagement with our Service;
• facilitate in-game purchases;
• personalize our Service;
• enable players to communicate with each other if applicable;
• provide technical support and respond to player inquiries;
• authenticate and/or verify individual identities;
• protect the safety and well-being of our players;
• protect Innplay Labs’ rights and property in connection with our Service;
• address technical issues and maintain and/or enhance network and information security;
• conduct audits, ensure internal quality control, and take safety precautions;
• prevent, investigate, and/or prosecute fraud or potentially illegal activities and enforce our Terms of Service;
• manage and deliver contextual and behavioral advertising;
• notify players of in-game updates, new products, content or promotional offers;
• administer and deliver rewards, surveys, sweepstakes, contests, gifts, and/or other promotional activities or events sponsored or managed by us or our business partners;
• comply with our legal obligations, resolve any disputes we may have with you or other players, collect any money owed us, and enforce our agreements;
• conduct research, including by using personal data to create de-identified and/or aggregated data. De-identified and aggregated data are not personal data, and we may use and share such data for any legally permissible purposes.

In addition to the above, if you have provided us with your e-mail address, we may use it to communicate with you in a number of ways, including to respond to customer support inquiries; keep you and others informed of your gameplay, comments from friends, and in-game status and promotions; and tell you about gift and neighbor requests. Some messages, like invitations for friends to join you in a game, may include your name and profile photo. We may also send promotional messages (“Promotional Communications”) if applicable. For more information on how you can opt-out of Promotional Communications, please see the Your Rights section below.

We may use technologies that (a) may be considered automated decision-making or profiling, and/or (b) include artificial intelligence to evaluate personal data that we collect (including, for example, in-game activity) to improve our Service (for example, personalize  the game experience, and understand trends in response to certain features in our Service) and for other legitimate business purposes. We will not use these technologies in a way that has a legally significant impact on you, unless we have your consent, or we are otherwise legally permitted to do so.

3. How we Share personal data.

We may share personal data with third parties or allow third parties to collect this information from our Service as described in this Privacy Notice.

Group companies. We may share your personal data with our group companies including Playtika Ltd and Playtika Holding Corp. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.

Service Providers, and Subcontractors. We may disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors (for example, to help us provide you with the Service in the Site and/or Apps or analyze data).

Advertising and user acquisition. We may have advertising on our Service. When advertisers or ad networks place ads in our Service, they may collect, or we may share the following types of information from within our Service:

• performance data (like the number of clicks on an advertisement);
• certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and device identifiers);
• in-game activity (for example, your level)

Please note, after clicking on a third-party advertisement, you may no longer be on a site hosted by Innplay Labs, in an application owned by Innplay Labs, or on the social network through which you are playing Innplay Labs’ games.

Business Transfers. If we undertake efforts to engage in a business transition (including but not limited to a merger with and/or acquisition by another company, or sale of all or part its assets), we may disclose relevant information we have, including personal data, to the successor organization in the transition. We will make reasonable efforts as described in this Privacy Notice to let you know of the business transition before transferring personal data to the extent required by law.

Law Enforcement Related Disclosure. We may share your personal data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.

4. International Transfer.

We may send, access, use, and/or store personal data outside of the country or region where you live including, for example, to the United States and Israel. We may transfer personal data to our subsidiaries, vendors, business partners, and others as described in this Privacy Notice.

Laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in place where you live. When we transfer personal data outside of the location where it was collected, we put into place appropriate safeguards (including, for example, contracts) or otherwise make efforts to ensure that such transfers meet applicable local legal requirements.

By using the Service, you consent to the transfer of personal data outside of the country or region where you live. If you do not consent to such transfer, please do not use our Service.

5. Security.

We have implemented and maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data and in accordance with applicable law. However, no system or network can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure.

6. Your Rights. Subject to applicable law and certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you might have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will make reasonable efforts to honor your request to exercise your rights within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests. In particular, depending upon the applicable law where you live, you may have the following rights:

• Right of Access. You may have a right to request information about Personal Data we process about you.

• Right to Data Portability. In some circumstances, you may request that we provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly used, and machine- readable format.

• Right to Correct Personal Data. Subject to the limitations in applicable laws, you may request that we correct inaccurate, incomplete, or outdated Personal Data about you.

• Deletion of Personal Data (“Right to Be Forgotten”). You may have the right to request we delete your Personal Data. We may retain certain Personal Data as permitted and/or required under applicable law.

• Right to Restrict or object In some cases, you may have the right to ask us to limit or stop the processing of your Personal Data.

• Right to Lodge a Complaint with Your Local Supervisory Authority. You may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data.

You can exercise these rights by sending a request to support@innplaylabs.com.  

• Choosing not to receive Promotional Communications.

If you want to stop receiving Promotional Communications, you can click on the “unsubscribe” link in any promotional email from us.

• Choosing not to receive Facebook messages.

If you want to stop receiving messages through our game pages on Facebook, you can turn off all messages through your Facebook “settings”.

• Choosing not to receive Push Notifications.

When you install our apps on your mobile device, you can choose to receive push notifications, which are messages an app sends you on your device even when the app is not on. You can turn off notifications by visiting your mobile device’s “Settings” or in the settings on the Apps.

• Choosing not to apply Cookie Tracking.

You can disable cookies tracking on our sites that uses cookies (see further information about cookies below) by adjusting your preferences using the cookie banner implemented in the Site. To your attention, if you disable cookies, you may lose some of the features and functionality of our Service.

• Opting Out of Third-Party Tailored Advertising.

In games that serve third-party tailored ads, we provide a toggle button to disable them in the App settings.

In addition, if you do not want to receive third-party tailored ads, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the advertising identifier (like an IDFA) from your device’s Settings, which will prevent continued use of existing behavioral data tied to the previous advertising identifier.

Please note that you may still receive advertisements from Innplay Labs and third parties within Innplay Labs’ games even if you opt out of tailored advertising; these ads will not be tailored to you.

7. Data Retention.

Subject to applicable law, we may retain personal data for as long as you use the Service and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.

8. Cookies and Similar Technologies.

Innplay Labs, our service providers, and other third parties may place cookies on your device when you access or browse the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes. Information contained in a cookie may be linked to personal data. We may use cookies for purposes such as help personalize your experience on our Site, improving the quality of our Service, making the Service easier to use, tailoring recommendations to interests and serving targeted ads. Third party advertisers may also use, place, or read cookies or other technologies on your device, and those practices are subject to their own policies.

We may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively by recognizing your device(s) on, off, and across different services and devices, and identifying the source of a new installation; and (iii) local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-game preferences, and speed up load times.

9. Links to Third-Party Applications and Services.

The Service may include links to other websites and/or applications that are owned and/or operated by others. Any information you provide on such websites and/or apps are subject to the privacy policy on such website or app, and Innplay Labs is not responsible for the content, privacy policy, terms of use, or security practices of such site and/or app. You should review the terms and privacy policy of any site or app that you access.

10. Communications.

We reserve the right to send you service-related communications, including service announcements and administrative messages.

11. Children’s Privacy.

In accordance with the Terms of Service, you may not use the Service if you are under 18 years old. We are committed to complying with laws protecting children. If you believe that your child has submitted personal data to us, please contact us at support@innplaylabs.com. We will take reasonable steps to delete such information as soon as possible.

12. Changes to the Privacy Notice.

We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we encourage you to consult the Privacy Notice regularly for changes. If we make material changes to our Privacy Notice, we will make reasonable efforts to inform you about the changes by placing a notice on our Site or in our Apps.

13. Contact, Comments and Questions. 
    If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, you can contact us at support@innplaylabs.com. Our registered office is Ha’sadnaot 8, Herzliya, Israel and our registration number is 516059656.
14. Supplemental U.S. State Laws Notice (“Supplemental Notice”)

Innplay Labs uses and shares information as described in this Privacy Notice. The information below supplements the Privacy Notice and is intended for consumers from select U.S. states, including California, Colorado, Connecticut, Utah, and Virginia in accordance with applicable state laws.

Collection and Use of Personal Information

“Personal Information” in this Supplemental Notice refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a certain consumer or household or as otherwise defined under applicable laws in California, Colorado, Connecticut, Utah, and Virginia.

The following chart lists the categories of Personal Information we collect about players, the source of collection, and the business purposes for collection. These are also the categories of Personal Information we collected in the past 12 months and their business purposes.

A more detailed description of the particular pieces of information we collect, and their purposes is provided in this Privacy Notice.

The following describes the categories of personal information we have shared for a business purpose in the past 12 months.

Innplay Labs permits, subject to legal and technical limitations, certain third-party advertising partners to collect information about our players through our games and our website for purposes ad campaign measurement and analytics, and for ad fraud detection and reporting. To the extent this practice is interpreted to constitute a “sale” and/or “sharing” under relevant state laws, please see our Online Advertising section below for more information.

To Whom We Disclose Personal Information

As described in this Privacy Notice, we disclose personal information within the Innplay Labs group of companies and with a variety of recipients for business purposes.

In addition to the categories of recipients identified in the How We Share Personal Data section of this Privacy Notice, we disclose personal information to, or allow access to personal information by, the following categories of recipients:

• Cloud Storage Providers
• Payment and Auditing Processors
• Security Safety Vendors and Service Providers
• Customer Service Vendors
• Advertising and Marketing Partners

Online Advertising

The following describes the categories of personal information we have shared for a business purpose in the past 12 months. When we serve you personalized video ads, we share your resettable identifiers provided by your mobile device’s operating system with ad networks, social media companies and other third-party businesses in the ad ecosystem. The typical resettable advertising IDs are GAID (Android) and IDFA (Apple). Third parties may use your personal information to:

• serve relevant ads on our site, on other websites or mobile apps, or on other devices a Player may use;
• to personalize content; and
• to perform other advertising-related services such as reporting, attribution, analytics and market research.

In addition, in some instances, third parties may use the information for their own purposes and in accordance with their own privacy policies and terms of use, which may include providing this information to additional third parties, including other advertising networks. Innplay Labs provides opportunities, where appropriate, for players to opt-out of the use and sharing of personal data about them for this purpose.

You may reset these identifiers from within your mobile device or limit ad tracking for your mobile device as mentioned above. Alternatively, you may also do so in the Advanced Settings of our games by changing the personalized/ tailored ads toggle to “off”. If you opt-out, you will still see ads, but they will be less relevant.

Additional Rights

As referenced above (“Your Rights”), you may submit a request to exercise certain rights through the Support page within the game you play. We will respond to your request in consistent with applicable laws and subject to adequate verification. We will verify your request by asking you to provide information necessary to verify your account.

You will not be discriminated against for exercising any of your rights. Please understand that, if the exercise of your rights limits our ability to process personal data (such as a deletion request), we may no longer be able to provide you with the Service.

You may appeal our decision regarding your rights request by sending an email to support@innplaylabs.com. We will review and arbitrate the appeal based on applicable laws.

Minors

As described in our Privacy Notice, we do not knowingly collect or share personal data about children.

Authorized Agents

You may be allowed to use an authorized agent to submit requests on your behalf, if you provide sufficient information to show that the requestor is an authorized agent with written permission to act on your behalf and you verify your identity with us.

Service Difference

In each of the following instances, which we occasionally offer on some, but not all games, we may grant you virtual currency or other virtual items within the game:

You have a right to withdraw from the service difference at any time. To do so, please submit a request through the Support section in the game settings or contact us via email to support@innplaylabs.com.