Last updated: 9 May 2023

OVERVIEW

This document explains what information is collected regarding the games published and services provided by Karma Games Limited - Also referred to in this document as "Karma".

It also explains how Karma uses that information, where Karma stores it and how Karma protects it.

Karma can share the information with partners for the purpose of providing the Games and services.

Karma will not share your information for third party advertising purposes.

This Policy sets out how your personal information is collected, stored and used when you play one of Karma's games (each a "Game" and together referred to as "Games") whether accessed by means of a web browser, social networking site or as apps via platforms (including but not limited to Apple AppStore, Google Play, Windows Phone, Android AppStore, Amazon AppStore) and what happens to it regarding any Karma services.

Karma respects your right to privacy and will only process personal information in accordance with applicable legislation in the European Union (which includes the General Data Protection Regulation (EU) 2016/679 or "GDPR" as it is often referred to), the United Kingdom (should it leave the European Union on 1 November 2019 or later, the United States of America and elsewhere.

Karma will store and use your information for as long as you use the Games, have an account with Karma or Karma considers it necessary to fulfil the purposes set out in this Policy which for the avoidance of doubt be different durations. You may at any time make contact us to receive an indication relating to the durations of the storage of the different forms of information (contact, sign-in, gaming history, payment, etc.)

If you have any queries, you can contact us at games@karma.co.uk

KARMA GAMES LIMITED

Karma Games Limited is incorporated and registered in England with company number: 12425040 having a registered office at 56 Short's Gardens, London, UK, WC2H 9AN and its group of companies ("Karma Games").

POLICY COVERAGE

This Policy explains the different kinds of information Karma may collect from you when you are using the Games whether by using the Games or contacting Karma by e-mail (either directly or through chat-room or social network function), telephone or fax. Legally, Karma cannot and will not collect personal information about children below 13 without parental/ guardian involvement. Karma will comply with applicable privacy laws.

By downloading and/ or accessing any of the Games you hereby agree to be bound by this Policy in respect of the information collected about you. Karma may from time-to-time change this Policy and at any time, for example to reflect changes in Karma's services or to reflect applicable laws. In the event that Karma makes material changes to the Policy we will make reasonable efforts to notify you prior to such change and update the "Last Updated" date. Once Karma changes the Policy, it will become legally binding on you as of the date of publication (i.e. the new "Last updated" date). Should you not wish to consent to the changes in the Policy you should stop using the Games. This Policy applies to people who use the Games and people who make complaints to us by e-mail. If you do not agree to those changes (regardless of whether you e-mail us), then unfortunately we must ask you to cease using all Games: in order to make the Games work properly Karma needs to have a regularised set of rules applying to all users.

This Policy applies to the Games, plus all other Karma products and services, including (but not limited to) user accounts, customer and technical support, official forums, wikis, blogs and social media services.

This Policy governs personal information (or, in the United States of America, personally identifiable information) and non-personal information (or, in the United States of America, non-personally identifiable information), which Karma collects from you when you are using the Games ("personal information" means information, which, on its own or in combination with other information, can be used to identify you).

Karma recognises that it has a special obligation to protect personal information obtained from children. Karma does not and will not knowingly collect personal information from any child under the age of 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal information about your child, please contact: games@karma.co.uk

If you are under 13 or a minor in your country of residence, you will need your parent or legal guardian's permission to use and access the Games. The Games may be intended for users aged 13 and above. However, the content of the Games has been rated by Apple as being acceptable for ages 13 and above. Karma does not request, seek, verify or track the age of its players, as such any individual who has access to a device of any age may play a Game and, in circumstances where the individual is unsupervised, make purchases without the device owner's permission or consent. Please be aware that it is the platform providers (Apple AppStore, Google Play, Windows Phone, Android AppStore, Amazon AppStore, etc.) and not Karma who control the payment process for in-app purchases. Therefore, any and all queries or application for refunds should be made directly to the platform provider. Information relating to the relevant complaints procedure will ordinarily be set out within the body of the invoices received from the platform providers.

Karma respects your right to privacy and will only process personal information in accordance with applicable legislation in the European Union, the United Kingdom (should it leave the European Union on 1 November 2019 or later, the United States of America and elsewhere. For personal information contained in this Policy which is used by Karma in connection with the Games, Karma is the data controller under European Union data protection legislation.

INFORMATION COVERED

Karma may collect certain information when you use the games such as your name and e-mail address, etc. Karma does not receive or store your payment details. Please also read our Cookie Policy below.

When you sign up for, download, use or play the Games Karma will collect certain information from you. This information may include: your name; your date of birth; your e-mail address; any user name used to identify yourself; photograph(s); avatar(s); details of your digital platform account; any other information which you supply us via our services (including the content of messages sent using any chat/ communications systems); technical details about any device which you use to access the Games, including: Internet and/ or network connection (including IP address); any mobile device identifier, MAC address or console device identifier; your operating system, browser type or other software; or your hardware or other technical details (this is technical data about our users and their actions and patterns which does not provide personal information); details of your use of the services (including, but not limited to, metrics information about when and how you use the services, traffic data, country of residence, contact information and your geographical location data). Karma may, at its discretion, create a unique user identifier to analyse your use of Games, this unique identifier may be stored with your personal information. The data collected in relation to your use of Games may include (but is not limited to): metrics information regarding how and when you play Games; language preferences; in-game purchases; achievements; scores; gameplay statistics and time spent playing Games.

If/when Karma decides to deploy social networking features in any of the Games, should you decide to link the Games to a social networking account(s), then Karma may collect details about your use of social networking account(s) and the services. This may potentially include certain information from Facebook, Twitter, Instagram, Snapchat, Tiktok or other social networks (including access to your name, location, gender, birth date, e

MISCELLANEOUS

Please be aware that Karma is or will be subject to various laws and Karma may be required to release personal information in order to comply with legal requirements.

Karma may transfer personal information to an associated third-party or Karma Group company who will protect this to at least the same level as Karma does in this Policy.

USER RIGHTS

You have rights about how your personal information is used, which can vary depending on where you live. You are entitled to access (with a corresponding right to rectify incorrect information), withdraw consent for, object to, restrict the processing of and erase your personal information. Should you wish to have your personal information erased Karma will remove all personal information from the Games and you will lose progress and in-app purchases. Karma will not be able to restore any erased information. If you have any questions, please contact Karma at: games@karma.co.uk

You have the right to ask Karma not to process your personal information for marketing purposes. You can change your e-mail settings to unsubscribe from e-mail communications.

Depending on where you live, you may have additional privacy rights. For example, in the European Union (under GDPR) you have the right to access the personal information that Karma possesses about you and you may have the legal right to contact Karma to request that we rectify any incorrect or incomplete data, erase, delete or block your personal information from Karma's system.

Karma will use reasonable efforts to deal with your request, but Karma may decline requests that are unreasonably repetitive, are disproportionate or infringe the privacy of others.

Under California law, California residents who have an established business relationship with Karma have the right to request certain information with respect to the types of personal information Karma has shared with third-parties for their direct marketing purposes, and the identities of those third-parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to: Karma Games Limited, 56 Short's Gardens, London, UK WC2H 9AN. This same California law permits Karma to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above-described information. You may exercise that choice by contacting Karma at the address above.

If you would like to exercise any of these rights or have any queries regarding them, please contact: games@karma.co.uk

KARMA GAMES LIMITED COOKIE POLICY

Last updated: 23 September 2019

Karma uses technologies in its games, its websites, all other Karma products and services (including, but not limited to, user accounts, customer and technical support, official forums, wikis, blogs and social media services) (the "Services") to collect information that helps Karma improve your online experience. Karma refers to these technologies, which include cookies, collectively as "cookies". This Policy explains the different types of cookies used on the Services and how you can control them.

Karma hopes that this Policy helps you understand and feel more confident about our use of cookies.

If you have any further queries, please contact us at games@karma.co.uk

Please also see our Privacy Policy above.

By accessing or using the Services you authorise Karma to collect certain technical information in order to:-

Karma, and Karma's third-party service providers, may use server log files or web log files and tracking technologies to collect and analyse certain types of technical information, including, but not limited to, cookies, IP addresses, device type, device identifiers, browser types, browser language, referring and exit pages, and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on the Services, the date and time you used the Services, error logs, and other similar information. As set out in our Privacy Policy, Karma may process and use this technical information to analyse usage of the Services, provide a more personalised experience, and manage advertising.

Karma may collect certain information about your use of the Services through the use of tracking technologies such as cookies and web beacons. Such collected information may include the content you view, the date and time that you view this content, the products you purchase, or your location information associated with your IP address. Third-parties, including advertisers and ad-related services, may also use tracking technologies on the Services to track your online activities over time and across third-party websites or online services. Karma does not currently process or comply with any web browser's "do not track" signal or similar mechanisms.

Karma may use cookies for various purposes, including to:

Karma may also permit third-party service providers to place cookies through the Services to:

If you are uncomfortable with Karma's use of cookies, you can disable cookies by changing the settings on your browser. Please be aware that disabling cookies may impair the functionality of the Services. For more information on how to disable cookies on your browser, please consult your browser's documentation.

Karma may use Adobe Flash technology (including Flash Local Shared Objects ("Flash LSOs")) and other similar technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the website storage settings panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Services or our online content.

Karma may use advertising networks and services provided by third-party ad technology vendors and providers ("Ad Providers"). Ad Providers may use tracking technologies to collect information about your visits to the Services and other websites and applications, and your interaction with our advertising and other communications. Ad Providers may use this information to provide advertisements on the Services and other websites and applications that are tailored to interests you have shown and/ or inferred from your online activity. Ad Providers may also use this information to determine the effectiveness of our advertising and to analyze other interactions with our advertising. If/when Karma uses the services of Ad Providers it currently uses them for targeting and retargeting services. For more information about targeting and retargeting and about how to opt-out of receiving targeted advertising from many Ad Providers, you can visit http://www.networkadvertising.org/choices/.

By using the Services you consent to the processing of data about you by Karma and any third-party Ad Providers, Ad Exchange and/ or data exchanges in the manner and for the purposes set out above. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features of the Services that rely on cookies.

For more information about Karma's advertising practices, please see the Advertisements and Promotions section of the Privacy Policy.

CHANGES TO THIS COOKIE POLICY

Karma may change this Cookie Policy from time to time. If Karma makes changes to this Cookie Policy, Karma will update the "Last Updated" date above. Karma will obtain your consent for any changes to this Cookie Policy that materially impact how Karma and the Services collect, use, or share your information. You can see when this Cookie Policy was last updated by reviewing the date above.