Effective Date: November 12, 2024

THE BOTTOM LINE

In addition to the information you provide, such as your username (and email address if you reach out for support), we collect details about your device and how you play our games to improve your experience. While some of our games may include third-party ads, you have control over what types of information our advertising partners can access. Some games include social features, but we only use social data to operate our service. For example, we may need to review posts to enforce our Terms of Service or fulfill legal obligations. We do not use your chat history for advertising purposes.

SCOPE AND UPDATES TO THIS PRIVACY POLICY

This policy covers your data as a player, regardless of where it is collected. Use our services only if you are comfortable with this policy, which we may update from time to time. This Privacy Policy applies to personal information processed by JSAStudios on our websites, mobile applications ("apps"), and other online or offline offerings. For simplicity, our websites, apps, and other services are collectively referred to here as the "Services." Changes to our Privacy Policy. We may revise this Privacy Policy at our discretion. Should there be material changes, we will notify you as required by law. Continuing to use our Services after updates means you accept the revised policy.

PERSONAL INFORMATION WE COLLECT

Like most mobile game developers, we collect information to improve our games. This includes your chosen nickname as well as any data we may collect from your device or from third-party services (like Facebook, Apple, or Google if you connect with them). The types of personal information we collect depend on your interactions with us and our Services, and on legal requirements. We generally collect personal information that you provide directly, obtain automatically when you use our Services, or receive from third-party sources.

Personal Information You Provide to Us Directly

We only request the information needed to run our games effectively. For example, if you use voice chat in some games, we need microphone access. We may also collect other information in specific situations, such as attending in-person events or joining promotional programs. We may collect personal information you provide to us. For example:

Information Required to Play: Personal information may be collected when you play our games, like the nickname you choose or your age in some games.

Content Creator Program: Some games have "partner" or "content creator" programs where players receive exclusive in-game benefits. If you apply, we may collect your full name, channel name, primary and secondary channel links, email address, subscriber/follower count, player ID, age, and optional country/region information and Discord ID. Please see our Content Partner Privacy Policy for more details.

Interactive Features: You and others may submit personal information through interactive features (e.g., chat, forums, social media pages). Some games may require microphone or photo library access for optional features.

Communications with Us: We may collect your name, email, phone number, or mailing address when you interact with us for support or other inquiries. Your Purchases: We may collect personal information related to purchases, such as transaction history, through third-party platforms like Apple and Google (though we do not store payment card information).

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We share your personal information with others to provide you with our Services. For example, we might share your data with our hosting providers or other players if you use our sharing features. We also share some of your details with third-party advertising partners, though you can control this (see below). Additionally, we might share your information when necessary to protect you or others, or when legally required, such as when law enforcement requests it, or if we undergo a corporate restructuring.

Disclosures to Provide Our Services

The third parties we may share your information with are listed below:

Service Providers: We may share your personal information with third-party service providers and vendors that help us deliver our Services, including IT support, hosting, payment processing, customer service, and related services.

Business Partners:We might share your personal information with business partners for the purpose of providing a product or service you have requested, or to jointly organize contests or events. We may also share data with partners with whom we offer products or services together.

Affiliates: We may share your information with affiliates for administrative purposes, IT management, or to support and supplement the services we provide.

Other Players or Third Parties You Interact With: As mentioned in the “Personal Information We Collect” section, you may share personal information through interactions with other players in our Services.

Advertising Partners: We may share your data with third-party advertisers. These partners may use tracking technologies to collect information about your activities and device (such as your IP address, cookie identifiers, pages visited, location, and time of day) for the purpose of serving personalized advertisements. This is known as “interest-based advertising” or “personalized advertising.”

APIs/SDKs: We may use third-party APIs and SDKs to provide certain functionalities within our Services. If you have questions about how we use these tools, please contact us via the details provided in the “Contact Us” section below.

Disclosures to Protect Us or Others

We may access, preserve, and disclose your information to third parties if we believe in good faith that it’s necessary or appropriate to: comply with legal requests, such as a court order or subpoena, protect the rights, property, or safety of yourself, us, or others, enforce our policies or contracts, collect amounts owed to us, assist in investigating or prosecuting suspected illegal activities.

Disclosure in the Event of Merger, Sale, or Asset Transfers

If we are involved in a merger, acquisition, or asset transfer, your information may be transferred as part of the transaction, in accordance with the law and contractual agreements.

YOUR PRIVACY CHOICES AND RIGHTS

You control your personal information. Besides device-specific controls, you can directly exercise your data rights with us. Depending on your location, you may request us to delete, modify, or provide a copy of your data in a portable format. For such requests or to learn more about your rights, contact us via our webform or email at info@jsastudios.com.

Your Privacy Choices

Email Communications: If you receive unwanted emails from us, you can unsubscribe using the link at the bottom of the email. Note that you will continue receiving transaction-related emails for products or services you’ve requested. You may also receive some non-promotional communications that you cannot opt-out of (e.g., updates to our Terms of Service or Privacy Policy).

Push Notifications: We may send push notifications through our mobile app. You can disable them in your mobile device settings.

Personalized Advertising: You can stop or limit the placement of tracking technologies by adjusting your browser or device settings. However, disabling some of these may affect the functioning of our Services. Note that cookie-based opt-outs do not work on mobile apps. You can also opt-out of personalized ads on some mobile apps through instructions for Android, iOS, or other platforms.

Targeted Advertising Opt-Out: The online advertising industry provides websites where you can opt-out of targeted ads from participating partners. Learn more about consumer choice and privacy by visiting organizations such as the Network Advertising Initiative and the Digital Advertising Alliance.

Do Not Track / Global Privacy Control: Do Not Track (DNT) is a setting you can enable in certain web browsers. Similarly, some browsers or plugins use a Global Privacy Control (GPC), which you can read more about at https://globalprivacycontrol.org/. Please note that we do not respond to DNT signals. However, if we detect a GPC signal, we will interpret it as a “Do Not Sell” request under applicable law, and also as a request to limit the sale or sharing of personal information for targeted ads in regions like the European Economic Area, UK, China, and Brazil.

Your Privacy Rights.

Access Personal Information: You can confirm whether we are processing your personal information, and obtain access to or a copy of it.

Request Correction: You may request the correction of any inaccurate, incomplete, or outdated personal information. In some cases, we may provide tools for you to update your personal data.

Request Deletion, Anonymization, or Blocking: You can request that your personal data be deleted, anonymized, or blocked when processing is based on your consent or when it is unnecessary, excessive, or non-compliant with regulations.

Request Restriction of Processing or Object: You may request a restriction on or object to our processing of your personal information if it is non-compliant.

Withdraw Consent: You may withdraw your consent to process your personal data. However, note that withdrawal will only apply to future processing, and will not affect the lawfulness of processing before the withdrawal. Withdrawing consent or not providing certain personal information may impact your ability to use some features of our Services.

Request Data Portability: You can request an electronic copy of the personal information you provided to us.

Be Informed about Third-Party Sharing: You have the right to know about the third parties with whom we share your personal information.

Request Review of Automated Decisions: If automated decisions that may affect your data subject rights are made, you have the right to request a review.

If you wish to exercise any of these rights, please submit a request via our webform or contact us as indicated in the "Contact Us" section below. We will process your requests in compliance with applicable laws.

RETENTION AND SECURITY OF YOUR INFORMATION

We retain your data only as long as reasonably necessary to operate our business, fulfill the purposes it was collected for, resolve disputes, perform audits, pursue legitimate business purposes, enforce agreements, and comply with the law. We have internal processes in place to protect your data from unauthorized access, but we cannot guarantee 100% security. We will notify you in the event of a breach, regardless of your email preferences. Rest assured, we are committed to safeguarding your information at JSA Studios. We store your personal information as outlined in this Privacy Policy for as long as you use our Services, or as long as needed to meet the purposes for which it was collected. We take steps to ensure that your data is processed securely, in accordance with this Privacy Policy. However, no system can be 100% secure, and we cannot guarantee complete protection of any data you provide. To the fullest extent allowed by law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information. By using our Services or providing us with your personal information, you agree to receive electronic communication related to security, privacy, and administrative issues. If a breach occurs, we will notify you electronically via our Services, by mail, or email.

INTERNATIONAL DATA TRANSFERS

As a global company, we operate in over 200 countries, which means your information may be transferred to various locations, such as the United States or Brazil, for processing and storage. Please be aware that privacy laws in these locations may differ from those in your country. However, we are committed to ensuring that your information remains protected, regardless of where it is stored. All data we process may be transferred, processed, and stored globally, including in countries like the United States, Brazil, or others with potentially different data protection laws. We aim to safeguard your information according to applicable laws. If we transfer personal data originating from the European Economic Area (EEA), Switzerland, or the United Kingdom (UK) to countries lacking adequate protection under applicable data protection laws, we may use EU Standard Contractual Clauses as one of the safeguards to support such transfers. For further information on the safeguards we use for international data transfers, please contact us as outlined in the “Contact Us” section below.

ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA, VIRGINIA, CONNECTICUT, UTAH, AND COLORADO

Residents of certain US states have additional rights and require specific disclosures, which are outlined below.

PERSONAL INFORMATION WE COLLECT AND SHARE

Depending on how you use our Services, the personal information we have collected in the past twelve (12) months, and the categories of third parties with whom we have shared this information, are detailed in the table below.

Category of Personal Information Collected by JSA Studios

Identifiers: Real name, alias, postal address, unique personal identifiers, online identifiers, IP address, email address, username, or similar identifiers. Shared with: Service providers, other players, third parties you interact with, advertising partners, data analytics providers. Sold/Shared with: Advertising partners and data analytics providers (only online identifiers).

California Customer Records Statute: Name, address. Shared with: Service providers, data analytics providers.

Protected Classification: Age. Shared with: Service providers, advertising partners, data analytics providers. Sold/Shared with: Advertising partners, data analytics providers.

Commercial Information: Purchases, property records, product or service preferences. Shared with: Service providers, advertising partners, data analytics providers. Sold/Shared with: Advertising partners, data analytics providers.

Internet or Electronic Network Activity: Browsing history, search history, interaction with websites or apps. Shared with: Service providers, advertising partners, data analytics providers. Sold/Shared with: Advertising partners, data analytics providers.

Sensory Data: Audio, electronic, or visual information. Shared with: Service providers, other players, advertising partners, data analytics providers. Sold/Shared with: Advertising partners, data analytics providers.

Inferences: Profile reflecting preferences. Shared with: Service providers, advertising partners, data analytics providers. Sold/Shared with: Advertising partners, data analytics providers.

Use of Personal Information

JSA Studios may use or disclose personal information as described earlier. Any new categories of personal information or uses will be communicated to users as required by law.

Sales/Sharing of Personal Information

JSA Studios does not “sell” personal information but may share data with third-party advertising partners for promotional purposes. You can limit this sharing by following the instructions in the “Your Privacy Choices and Rights” section.

Your Rights and Choices

California, Virginia, Connecticut, Utah, and Colorado residents have the following rights:

To Know and Access: Request a copy of the personal information we have collected.

Deletion: Request deletion of your personal information, subject to applicable laws.

Opt-Out: Opt-out of the sale and sharing of personal information, including targeted advertising.

Correction: Request corrections to inaccurate personal information.

Disclosure: Request information about our data practices.

These rights are subject to verification and applicable law. If we are unable to process a request, we may ask for additional information.

Verification and Appeal: We verify identity before responding to requests. If your request is denied, residents of Colorado, Virginia, or Connecticut may appeal.

Authorized Agent: You may use an authorized agent to request privacy rights, provided proper authorization is given.

Referral and Promotions: We may offer incentives for referring others or participating in promotions. These programs are voluntary, and you can withdraw at any time.

Shine the Light Disclosure: California residents can request a notice detailing the categories of personal information shared for marketing purposes.

De-Identified Information: We do not attempt to re-identify de-identified information except to comply with applicable law.

Children’s Information: We take steps to limit access to services for children. Parents can contact us to review or delete their child’s information.

Other Provisions

Third-Party Websites: We are not responsible for the privacy practices of third-party sites.

Supervisory Authority: If you are in Australia, Brazil, the EU, Switzerland, or the UK, you can lodge a complaint with the relevant authority.

CONTACT US

If you have questions or want to exercise your privacy rights, contact us at info@jsastudios.com.