Privacy

## **Privacy Policy**

Play By Turns Ltd.  respect the privacy rights of our users and are committed to protecting the information collected through Attack By Turns and other products (together “Services”). Play By Turns Ltd.  has adopted this privacy policy (“Privacy Policy”) to explain how Play By Turns Ltd.  collects, stores, and uses the information collected in connection with Play By Turns Ltd. 's Services. Should you have any questions relating to this Privacy Policy, please contact us at info (at) attackbyturns.com.

BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES.

Play By Turns Ltd.  reserves the right to modify this Privacy Policy at reasonable times, so please review it frequently. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

### Non-personal data:

For purposes of this Privacy Policy, “non-personal data” means information that does not directly identify you. Additionally, non-personal data means “aggregate” and “de-personalized” information, which is data Play By Turns Ltd.  collects about the use of Play By Turns Ltd.  Services, from which any personally identifiable data has been removed. Play By Turns Ltd.  may use tools or third party analytical software to automatically collect and use certain non-personal data that does not directly enable Play By Turns Ltd.  to identify you. The types of non-personal data Play By Turns Ltd.  may collect and use include, but are not limited to: (i) device properties, including, but not limited to unique device identifier or other device identifier ("UDID"); (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) geographical data such as zip code, area code and location; (v) game score and achievements; (vi) other non-personal data as reasonably required by Play By Turns Ltd.  to enhance the Services and other Play By Turns Ltd.  products and services. Play By Turns Ltd.  may use and disclose to Play By Turns Ltd. 's partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, advertisement serving, managing and providing the Services and to further develop the Services and other Play By Turns Ltd.  services and products. You recognize and agree that the analytics companies utilized by Play By Turns Ltd.  may combine the information collected with other information they have independently collected from other services or products relating to your activities. These companies collect and use information under their own privacy policies.

### Ad Serving Technology:

Play By Turns Ltd.  reserves the right to use and disclose the collected non-personal data for purposes of advertisement by Play By Turns Ltd.  or Play By Turns Ltd. ’s partners and contractors. Play By Turns Ltd.  may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services. Play By Turns Ltd.  or third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service. Play By Turns Ltd.  or third parties may collect and use data for this purpose including, but not limited to IP address (including for purposes of determining your approximate geographic location), UDID, software, applications, hardware, browser information, internet and on-line usage information and in-game information. The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology. You recognize and agree that the advertising companies who deliver ads for Play By Turns Ltd.  may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies are integrated into Services; if you do not want to be subject to this technology, do not use or access Services. Although Play By Turns Ltd.  takes commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, Play By Turns Ltd.  does not have access to or control of third party technologies.

### Personal Data:

For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual. Likely situations when you make personal data available to Play By Turns Ltd.  include, but are not limited to: (i) registration for Services, contests and special events; (ii) accessing Services using a third party ID, such as social networking sites or gaming services; (iii) subscribing to newsletters; (iv) purchasing a product or services through Play By Turns Ltd. ’s online stores; (v) using “tell a friend,” "email this page," or other similar features; (vi) requesting technical support; and (vii) otherwise through use of Play By Turns Ltd.  Services where personal data is required for use and/or participation. The types of personal data may vary depending on the type of activity you are engaged in. The personal data Play By Turns Ltd.  may collect and process may include, but are not limited to your name, screen/nick name, Play By Turns Ltd.  Services’ or third party service ID, e-mail address, phone number, photo or other image, birthdate, sex, address, friend connections, avatar image, credit card information, shipping information; and location (only if directly identifiable to you, otherwise we treat location as non-personal data). Play By Turns Ltd.  may use collected personal data for purposes of analyzing usage of the Services, providing customer and technical support, managing and providing Services (including managing advertisement serving) and to further develop the Services and other Play By Turns Ltd.  services and products. Play By Turns Ltd.  may combine non-personal data with personal data. Please note that certain features of the Services may be able to connect to your social networking sites to obtain additional information about you. In such cases, Play By Turns Ltd.  may be able to collect certain information from your social networking profile when your social networking site permits it, and when you consent to allow your social networking site to make that information available to Play By Turns Ltd. . This information may include, but is not limited to, your name, profile picture, gender, user ID, email address, your country, your language, your time zone, the organizations and links on your profile page, the names and profile pictures of your social networking site “friends” and other information you have included in your social networking site profile. Play By Turns Ltd.  may associate and/or combine as well as use information collected by Play By Turns Ltd.  and/or obtained through such social networking sites in accordance with this Privacy Policy.

### Disclosure and Transfer of Personal Data:

Play By Turns Ltd.  collects and processes personal data on a voluntary basis and it is not in the business of selling your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy. Play By Turns Ltd.  may hire agents and contractors to collect and process personal data on Play By Turns Ltd. ’s behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Play By Turns Ltd. . These agents and contractors may not use your personal data for their own marketing purposes. Play By Turns Ltd.  may use third party service providers such as credit card processors, e-mail service providers, shipping agents, data analyzers and business intelligence providers. Play By Turns Ltd.  has the right to share your personal data as necessary for the aforementioned third parties to provide their services for Play By Turns Ltd. . Play By Turns Ltd.  is not liable for the acts and omissions of these third parties, except as provided by mandatory law. Play By Turns Ltd.  may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Play By Turns Ltd.  to legal liability. Play By Turns Ltd.  may also disclose your personal data to third parties when Play By Turns Ltd.  has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Play By Turns Ltd. ’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Play By Turns Ltd.  believes that such disclosure is necessary to protect Play By Turns Ltd. ’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Play By Turns Ltd. .

### Data Retention and Correctness:

Play By Turns Ltd.  retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Play By Turns Ltd.  deletes all aforementioned data in its possession. Play By Turns Ltd.  does not verify the correctness of personal data. Even if data is changed or deleted, Play By Turns Ltd.  may still retain some of the data to resolve disputes, enforce Play By Turns Ltd.  user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

### Cookies and beacons:

The Services may use “cookies” and other technologies such as pixel tags, clear GIFs and web beacons. Play By Turns Ltd.  treats information collected by cookies and similar technologies as non-personal data.

### Third Party Terms and Conditions:

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services and payment providers. You recognize and agree that Play By Turns Ltd.  is not liable for any such third party terms and conditions and their use of your personal data. Play By Turns Ltd.  may in its discretion make available links through advertisements or otherwise enable you to access third party products or services. Please note that, while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by Play By Turns Ltd. . Play By Turns Ltd.  is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that Play By Turns Ltd.  is linking to those products or services does not constitute our sponsorship of, or affiliation with, those people or companies. Please note that certain Services that Play By Turns Ltd.  may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the Services with a gaming console ID, social networking ID or gaming network account. When you register to join or use the Services from a third-party gaming or social networking system, certain personally identifiable user and/or membership data may be transferred automatically to and from Play By Turns Ltd.  and you hereby consent to the processing, combining, disclosing and retaining of such data in accordance with this Privacy Policy by Play By Turns Ltd. .

### Safeguards:

Play By Turns Ltd.  follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Play By Turns Ltd. ’s possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in Play By Turns Ltd. ’s possession. Personal data collected by Play By Turns Ltd.  is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, Play By Turns Ltd.  maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite Play By Turns Ltd. ’s reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.

### Other:

Please be aware of the open nature of certain social networking and other open features of the Services Play By Turns Ltd.  may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any Data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. Play By Turns Ltd.  is not responsible for any personal data you choose to make public in any of these forums. If you are under 15 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access the Services. Play By Turns Ltd.  takes children’s’ privacy seriously, and encourages parents and/or guardians to play an active role in their children's online experience at all times. Play By Turns Ltd.  may store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy. In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event involving all or a portion of Play By Turns Ltd. , Play By Turns Ltd. ’s customer information may be transferred to Play By Turns Ltd. ’s successor or assign.

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