Global Mobile Privacy Policy

(Last Updated: March 25, 2021)

This Privacy Policy applies to the "The Walking Dead: Survivors" app (the "App"). Unless otherwise stated when we collect your personal information, it does not apply to information collected outside of the App.

This Privacy Policy explains how we collect, store, use, disclose, and manage your personal information.

*Please note that the App is not directed to or appropriate for users under 18 years old.*

You can navigate to the relevant sections of this Privacy Policy using the buttons below.

If you do not [agree] with our Terms of Service, please do not access or use our Application. 

WHO WE ARE     +

NOTE TO PARENTS    +

TYPES OF INFORMATION WE COLLECT +

CHAT CONTENT +

HOW WE USE YOUR INFORMATION +

LEGAL GROUNDS FOR USING YOUR INFORMATION +

HOW WE SHARE YOUR INFORMATION +

LINKS TO THIRD PARTY CONTENT +

SECURITY +

YOUR PRIVACY RIGHTS +

DATA RETENTION POLICY +

INTERNATIONAL DATA TRANSFER +

CHANGES TO THIS PRIVACY POLICY +

CONTACT US +

WHO WE ARE

Beijing Elex Technology Co., Ltd. ("ELEX,""we,""our" or "us") is the operator and controller of the App. We respect the privacy rights of our  users ("you","users" and "user").

We are a valid licensee and participating member of the Entertainment Software Rating Board’s Privacy Certified Program ("ESRB Privacy Certified"). To protect your privacy, we have voluntarily undertaken this privacy initiative and have had the App reviewed and ESRB Privacy Certified to meet established online information, collection, use, and disclosure practices. As a licensee of this privacy program, we are subject to audits of the Application and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

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Types of Information We collect

ELEX collects information you may provide directly via the Application, certain technical information automatically, and information from third parties. Some of the information we collect may identify you personally (whether alone or in combination). This is considered personal information.

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TYPES OF INFORMATION WE COLLECT AND SOURCES OF INFORMATION

We collect three main sources of personal information: (1) information you provide by interacting with our App; (2) information provided by your device, and (3) information from third-party sites or platforms that you link with your registration account.  

The categories of information we collect are identifiers/contact information, demographic information (such as gender and age), commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.

This includes:

· personal information you provide when you create an account, contact us to request customer support or make a purchase, e.g. first name, surname, country of residence, email address, username, password;

· other personal information you provide when interacting with the App, e.g. information you provide in one-to-one, group, Clan or State chats, photos that you upload as an avatar or to customer support;

· personal information provided to us when you link to a third-party service (e.g. Google/Facebook) with your TWD account, e.g. encrypted ID information that allows us to save your game progress, your name and your profile picture;

· information collected automatically from and about the device(s) you use to access the Application (e.g. Internet Protocol (IP) address, type of device, operating system, language settings, device IDs, mobile advertising IDs (e.g., for Android users, the GPS ADID also known as the "Google Play Services ID for Android"), usage data (including the features of the App you use, and when and how often you use the App), and general location (country and, at times, city). This information is collected automatically using third-party SDKs or software development kits. An SDK is a code embedded in an app that sends information about your use to a server. The SDKs incorporated into the Application are as follows:

You are not obliged to provide us with any personal information. However, only those with an account on the App can use it. In addition, some parts of the App may be unavailable or may not function as intended without relevant personal information being provided (e.g. you will not be able to use the chat function without providing content to the chat; you will not be able to play your game on multiple devices without linking to a Facebook or Google account that is accessible from those devices).

The App should not be used to – and nor do we seek to – capture any sensitive persona date, i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or criminal behavior; genetic data, biometric data, health data; or data concerning a person’s sex life or sexual orientation.

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CHAT CONTENT

Content that you choose to include in chats (e.g. one-on-one chats, State chats, Clan chats, group chats, chats with Customer Service) will be visible to the audience included on your chat. Please do not include anything in a chat that you do not wish the relevant audience to see. [When users are added to an existing chat, they will be able to see any earlier discussion threads.] Please take care whenever you disclose personal information to other users or in non-private forums. We cannot control the way in which others use the information you have posted in these forums. If you believe that another user is improperly collecting or using information about you or other users, please <jump=Contact Us>.

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HOW WE USE YOUR INFORMATION

We may use the personal information collected from you or your device(s):

· to operate, manage, and provide you with, the App;

· to process payments and perform services requested by you;

· to communicate with you, including in response to any customer service requests that you make;

· to send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;

· to monitor and analyze aggregate trends, usage and activities;

· to improve the App or other ELEX websites, applications, products, or services (including for internal research and demographic studies);

· to send you messages or personalized information about our games, your scores, new features, contests, special offers, and more, including for marketing and promotional purposes;

· to provide you with targeted advertisements, marketing and promotional materials and to measure their effectiveness where lawful (N.B. you may still view non-targeted marketing in-App even if you choose not to receive targeted marketing);

· to prevent and address fraud, breach of policies or terms, and threats of harm;

· to share information with a third party who takes over any or all of our assets (in which case personal information we hold about you may be one of the assets the third party takes over).

[If you choose to share your personal information with us in connection with a customer service request, we will use that information [solely] to address your customer service request. ]

We may also use this information for other purposes from time to time. Where this is the case, we will only do so where those purposes are compatible with the purposes set out above or (where applicable) for which you provide affirmative consent.

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LEGAL GROUNDS FOR USING YOUR INFORMATION

We process your personal information for the purposes set out in this Privacy Policy. We normally process personal information as necessary to provide the services set out in a contract, when it is in our or a third party’s legitimate interests or where it is required or allowed by applicable laws. We must have a lawful reason for processing your Personal Information. In the Europe, our legal basis will usually be one of the following grounds:

· performance of a contract – where processing is necessary to perform our contract with or provide services to you, for example, processing that we carry out to comply with our obligations under our terms of service;

· legitimate interests – we process your personal information where it is in our or a third party’s legitimate interests and that legitimate interest is not overridden by your interests or your fundamental rights or freedoms. These legitimate interests include:

o responding to your queries and questions;

o ensuring the proper functioning and security of our websites, applications, products and services;

o improving, operating and managing our business and the websites, applications, products and services that we offer, including monitoring and analysing trends for research and development;

o preventing fraud, abuse, online grooming and other criminal activities;

o providing a personalized experience, including tailoring content and resources to your preferences and your device;

o effectively marketing, promoting and advertising our business, our websites, applications, products and services;

o meeting our corporate and social responsibility objectives; and

o enabling our partners to effectively market, promote and advertise their business, websites, applications, products and services.

· consent – if we are relying on consent, we will always explain this to you and obtain a clear, affirmative indication that you consent. Whenever we rely on consent, you have the right to withdraw your consent at any time. If you would like to withdraw your consent to any processing, please <jump=Contact Us>; and 

· compliance with legal obligations – where processing is necessary to meet our legal or regulatory obligations, such as in the case of disclosures to governmental or regulatory authorities;

· legal claims – where we need to establish, make or defend legal claims; and

· public information – we may process information that you have made public, e.g. in open chat forums.

In limited circumstances, we may also process personal information where it is necessary to protect the vital interests or safety of you or someone else (for example, in the case of a threat of harm) or for reasons that are in the public interest.

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HOW WE SHARE YOUR INFORMATION

We share personal information about you in the circumstances set out below.

· Within Elex’s Group: We may share your information with our related entities, including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing, or technical operations. Where we share your personal information with our affiliates, they handle your personal information in accordance with this Privacy Policy.

· Third Party Providers.  We share your information with our third-party service providers, which may include agents, vendors, and consultants, among others. Service providers assist us with operating the App and provide us with other services, including marketing and promotional services. We put in place terms with our third party providers to protect your personal information in accordance with the law.

· 

· Security and Compelled Disclosure.  We may share your information to comply with the law or other legal processes, and where required, in response to requests by public authorities, including to meet national security or law enforcement requests. We may also share your information in connection with an investigation of fraud, harassment, intellectual property infringements, or other activity that is illegal, a violation of our policies, or may expose you or us to legal liability. We may also share your information to protect the rights, property, life, health, security, and safety of us, the Application or a third party.

· Mergers or Acquisition.  In the event of, or during negotiations of, an actual or proposed merger, acquisition, reorganization, bankruptcy, or other similar event, your information may be shared with ELEX's successors or assigns or other third parties (including professional advisers) involved in the event.

Marketing and Advertising We also share personal information with our Marketing and Advertising Partners in order to market our App and to present advertising in the App as follows:

• Marketing Partners.  We share your information, including personal information, with our partners in connection with offering you co-branded services, marketing, promoting, advertising selling or distributing our products or the products of our partners, or engaging in joint marketing activities.

• Advertising Partners. We share your information, including advertising IDs, with third parties for purposes of providing you with advertisements. Our advertising partners include Facebook and Google, but we may use other advertising partners as well.

If you do not want to receive personalized  marketing and advertising, you can:

• Ask Adjust to forget your device: https://www.adjust.com/forget-device/

• Ask Appsflyer to forget your device: https://www.appsflyer.com/optout

• Change your settings on Google Play by opening the Google settings app on your device (called Google Settings or Settings, depending on your device) Scroll down and tap Google Tap Ads Switch on Opt out of interest-based ads or Opt out of Ads Personalisation.

• Opt out of personalized ads from Unity Ads that are presented in the game by click ing the privacy icon in the left bottom corner of a Unity ad.

• Opt out of receiving personalized ads in your Facebook account.

We may share aggregated information that does not specifically identify you or de-identified information about you with third parties or affiliates for any purpose, except as prohibited by law.

Except as set out above and in this Privacy Policy, we do not disclose, sell or rent your personal information to any third parties.

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LINKS TO THIRD PARTY CONTENT

The App may contain links to third-party websites or other online services. When you provide information to a third-party website or other online service, that information may be separately collected by the third party and is subject to the third-party site or platform’s privacy practices (and not this Privacy Policy). Privacy choices you have made on the third-party websites or other online services will not apply to our use of the information we have collected directly through the App.

We are not responsible for the content or the privacy policies or practices of any other websites or online services, or for the actions of the companies responsible for those websites and online services. Please review the privacy policies of those websites or online services before providing them with any personal information.

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SECURITY

The security of your information is important to us. We take steps designed to protect the security and integrity of information you provide to us. [We regularly assess our security procedures and implement appropriate new technology and safeguards.] Nevertheless, transmission via the internet is not completely secure and no security measures are impenetrable. 

Please also remember that you are responsible for maintaining the secrecy of your passwords and account information. Please be careful and responsible whenever you are online.

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YOUR PRIVACY RIGHTS

Under laws in certain countries (which include countries within the European Economic areas), you may have the following rights:

· Access: you may request details of your personal information and a copy of that personal information.

· Rectification: you may have inaccurate information about you corrected or removed.

· Erasure: you may require certain personal information about you to be deleted from our records.

· Restriction: you may ask us to use your personal information for restricted purposes only.

· Objection: you may object to us processing your personal information where we process your information for our or a third party’s legitimate interests. In addition, you have the right to object to our use of your personal information for purposes of targeted or interest-based advertising at any time, or in certain circumstances where we rely on legitimate interest as the legal basis for our processing. For more information on interest-based advertising and opt-out options, see https://youradchoices.com/learn. 

· Data portability: you may ask us to transfer the personal information you have given us to you or to someone else in a format that can be read by computer.

· Withdraw consent: You may withdraw any consent you have given us to handle your personal information. If you withdraw your consent, this may impact your ability to use the App or related services, and it will not impact any processing of your personal information that has already taken place. 

Please note: Other than your right to object to us using your information for direct marketing, your rights are not absolute. This means they do not always apply in all cases, and if this is the case we will let you know when we respond to your request.

You may exercise or find out more about these rights by using the information in the <jump=Contact Us> section below.

CALIFORNIA RESIDENTS

California Consumer Privacy Act

This Privacy Policy complies with the California Consumer Privacy Act (CCPA), which requires that we provide California residents with notice that they have certain rights, how to exercise those rights and that you will not be discriminated against if you exercise these rights.

• You have the right to know about personal information we collect, disclose or sell.

This Privacy Policy contains information regarding the sources from which we collect personal information, which can be found above in the section titled "Type of Information We Collect and Sources of Information"; business and commercial purposes for which we collect your personal information, which can be found above in the section titled "How We Use Your Information"; and categories of recipients with whom personal information is shared or sold, which can be found in the section titled "How We Share Your Information." 

You may request a copy of the personal information we have collected from you and the categories of businesses we have transferred it to  by contacting us at legalprivacy@elex-tech.com or by submitting a request at <LINK TO FORM>.  We may verify your identity before providing personal information to you.

• You have the right to opt-out of the sale of personal information.

California residents have the right to opt out of the sale of personal information, which is defined in a way that may include the transfer of data to third parties to personalize the ads you see in the App or to market our Apps others. As described above in "How We Share Your Information", we transfer personal data including identifiers/contact information, demographic information (such as gender and age), commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above to our Marketing and Advertising partners listed in "Marketing and Advertising" and you may opt-out directly through those partners as described.  

You or your authorized agent may also opt out of the ‘sale’ of your information by contacting us at legalprivacy@elex-tech.com or by submitting a request at <LINK TO FORM>, and we will not transfer your personal information after you opt-out to our advertising partners. You will still see ads in the game, they will just be less relevant to you.

• You may request deletion of personal information

You can delete all personal information we have about you by accessing the settings in your game or by submitting a request at <LINK TO FORM>

• You will not be treated with discrimination should you exercise these rights.

For any questions or concerns about our Privacy Policy or practices, please contact us at privacy@elex.com

California Shine the Light Law

If you are a resident of California, section 1798.83 of the California Civil Code allows you to request information about the disclosure of your personal information to third parties for their direct marketing purposes.  You may submit such a request in writing to:

ELEX

97 E. Brokaw Road, Suite 310, Room M

San Jose, CA 95112

ATTN: Privacy

DO NOT TRACK

Your browser may allow you to set a "do not track" (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, our system does not support DNT signal headers that we may receive. However, the choices that we provide you concerning collection and use of your personal information will continue to operate as described in this Privacy Policy.

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DATA RETENTION POLICY

We set retention periods for personal information taking into account the following criteria:

the purpose for which it was collected;

· how long it is reasonable to keep records to show we have met the obligations we have to you and by law;

· any time limits for making a claim or for relevant proceedings; and

· any retention periods for information that are required or permitted by law or recommended by regulators, industry bodies or associations.  

[If you have not logged into or used the Application for two (2) consecutive years, we will generally either delete it or anonymize it so that it cannot be linked back to you. Any personal information you provide in connection with a customer service request or inquiry will be generally deleted by our third-party service provider one year from the date of your request or inquiry.]

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INTERNATIONAL DATA TRANSFER

Our games are played online by players around the world, using global platforms and systems. This means that your personal information may be transferred outside of your home country, including outside the European Economic Area (EEA).  

Not all countries will have data-protection laws in place that are similar to those in your home country. For example, if you are in Europe, your data may be transferred to a country that the European Commission does not recognize as providing an adequate level of data protection.

Personal data collected from individuals, including those in the EEA, is stored on servers located in the United States and the Netherlands. [We have verified that our Cloud Service Provider and data processors (where applicable) are certified under the EU-U.S. Privacy Shield Framework. For additional information, please click <ibm=here>.]

When we transfer your personal information to another country, we take steps to ensure that appropriate protections are in place in line with data-protection laws. Often, this protection is set out under a contract with the organization who receives that information. If you would like more details about the safeguards in place to ensure appropriate protection for international transfers of personal information, please <jump=Contact Us>.

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CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time. The Privacy Policy will indicate the date it was last updated. If we make a material change in the way we handle your personal information, we will provide you with additional notice by sending you an email at the last email address we have for you, if any, or by prominently posting notice of the change on the App. If you do not agree with any changes we make to the Privacy Policy, please stop using the App.

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CONTACT US

If you have any comments, questions or complaints regarding this Privacy Policy or our privacy practices, or other GDPR-related matters in the EU please contact us using any of the following methods:

ELEX

97 E. Brokaw Road, Suite 310, Room M

San Jose, CA 95112

Customer Service: support__app__303@mail.aihelp.net

Privacy Issues: aoe_help@elex.com

EU/EEA Representative

The nominated Representative for data protection matters within the EEA, pursuant to Article 27 of Regulation (EU) 2016/679 (the General Data Protection Regulation, or GDPR) is:

Adaptant Solutions AG

Rosenheimer Str. 139

81671 Munich

Germany

compliance-elex@adaptant.io

Inquiries may also be submitted through Adaptant’s contact form at https://www.adaptant.io/contacts-locations/.

ESRB Privacy Certified and Supervisory Authorities

As previously mentioned, ELEX is a licensee of the ESRB’s Privacy Certified Program. If you believe we have not adequately responded to your privacy-related inquiry or complaint, you may contact ESRB Privacy Certified at: ESRB, privacy@esrb.org.  

You also have a right to make a complaint to your local based in the country or territory where you live, you work or the matter you are complaining about took place. A list of the European Union’s privacy supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

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