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Supplemental Privacy Disclosure for California Residents


Last Updated: July 16, 2020.

The California Consumer Privacy Act of 2018, as amended (“CCPA”) establishes specific rights for California residents to control their personal information and requires businesses to provide specific information to California residents regarding how their personal information is collected, used, and shared.

Tilting Point Media LLC (referred to as “Tilting Point”, “we”, “us”, or “our” in this Disclosure) provides this Disclosure (“Disclosure”) to California residents who use our Services, including our Websites and our Games (referred to as “you” in this Disclosure) to provide you the information required by the CCPA and to inform you of your rights under the CCPA. This Disclosure supplements our Privacy Policy., which provides more comprehensive information on how and why we may process data relating to you. We recommend that you read our Privacy Policy in conjunction with this Disclosure.

In this Disclosure, the terms “Services”, “Games”, and “Websites” have the same definitions provided in our Privacy Policy..

1. Your Rights

Under the CCPA, California residents have certain rights to their personal information. If you are a California resident, you may exercise these rights as explained below.

When you submit a request to exercise your rights, we are required to verify that you are the consumer to whose personal information the request relates or a person authorized to act on that consumer’s behalf. If you submit your request using the automated tools provided in our Games, we will usually not need additional information to verify your request. For requests submitted by other means (for example, by email), we may ask you to provide additional information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf.

Right to Know. You have the right to know what personal information about you we collect, from which sources, for which purposes, and with whom we share it. You also have the right to request the specific pieces of personal information we have collected about you. This request can be made free of charge twice in any 12-month period. Moreover, you have the right to know which categories of personal information we have sold or disclosed for a business purpose.

For information on what personal information we collect, from which sources, for which purposes, with whom we share it, and whether we disclose it for business purposes, please refer to section 2 of this Disclosure. In addition, section 3 of this Disclosure describes the extent to which we may “sell” your personal information in the meaning of the CCPA.

You may request a copy of your personal information by contacting us at privacy@tiltingpoint.com. For more information, please refer to section 9 of our Privacy Policy..

Following your deletion request, we may either erase or de-identify your personal information.

Right to Opt-Out. You have the right to direct us to not “sell” your personal information (please see Section 3 of this Disclosure for further details on what this means under the CCPA and the situations in which we might do so). If you decline to give consent or contact us to opt out, we will no longer share your identifiers and other information with our ad partners to make the ads you see more relevant to you. To exercise your right to opt-out, please contact us at privacy@tiltingpoint.com or decline to give consent to such sharing within a Game when you see a message asking for consent.

Non-Discrimination. You have the right to not be discriminated against for exercising your rights under the CCPA.

2. How we collect, use, and share your personal information

What follows is a summary of how we may collect, use, and share your personal information. the summary is provided in the format we believe to be required by the CCPA. Please review our Privacy Policy. for additional information.

We regularly collect the following categories of personal information specified in the CCPA:

Category of personal informationExamplesSources
IdentifiersIn-game alias, IP address, hardware or operating system based identifiers, email address, or identifiers we assign to your account.Directly from you (including automatically when you interact with our Games), our advertising partners (to the extent you interact with our ads outside of our Games), third-party account providers (if you link a third-party account to our Games), or third-party payment service providers (if you make purchases in our Games).
Commercial informationInformation regarding your virtual items or currency in our Games, including records of purchases you may have made.Directly from you (including automatically when you interact with our Games) and third-party payment service providers (if you make purchases in our Games).
Internet or other electronic network activity informationInformation on your activity in our Games (for example, your game progress or your interactions with ads in our Games).Directly from you (including automatically when you interact with our Games), our advertising partners (to the extent you interact with our ads outside of our Games).
Geolocation dataYour coarse location (for example, country, state, or city), determined based on your IP address.Directly from you (including automatically when you interact with our Games).
Inferences drawn from this information to create a profile about youYour geolocation or preferences used to personalize our Games for you.We make these inferences based on the other categories of information.


We may use this information for the following business purposes specified in the CCPA:
  • auditing related to an interaction with you and concurrent transactions,
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity,
  • debugging to identify and repair errors in our services,
  • short-term, transient uses,
  • performing our services,
  • internal research for technological development and demonstration, or
  • activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
We may share the information with recipients such as our service providers to achieve these business purposes. This means that we may disclose the categories of personal information listed above for a business purpose.

In addition, some features of our Games (for example, in-game chat, surveys, or tools used to contact our player support) may allow you to submit information about yourself to us. We may collect any information you choose to submit to us using these features. In addition to the personal information listed in the table above, this may include other categories of personal information specified in the CCPA, including:
  • characteristics of protected classifications under California or federal law (for example, sex or age),
  • any categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code,
  • professional or employment-related information, or
  • education information (defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act).
We only collect these categories of personal information directly from you, and you may choose not to submit this information to us at your discretion. We may use the personal information you choose to submit for performing our services (for example, to handle your support enquiries) and short-term, transient uses, and we may share the information with recipients such as our service providers to achieve these business purposes. This means that we may disclose these categories of personal information for a business purpose.

3. How we may sell your personal information

Under the CCPA, a business is required to provide notice to a consumer before the business sells the consumer’s personal information to third parties. the CCPA defines a “sale” as not only exchanges for monetary consideration, but also Disclosures of personal information for other valuable consideration.

We do not sell your personal information in exchange for money. However, we may disclose a limited amount of your personal information (i) to our advertising partners to enable them to deliver an ad that is relevant to you or (ii) to our marketing partners to enable them to send you relevant offers when you have opted in to such communication. This includes the following categories of your personal information:
  • identifiers (generally including an advertising ID and your IP address for ad partners and name and email for marketing partners); and
  • internet or other electronic network activity information (including technical information required to select and deliver the appropriate ad type and format).
Because this disclosure of information could be deemed a “sale” in the meaning of the CCPA, we either ask for your explicit consent or provide a means for you to direct us to not disclose your personal information to our advertising or marketing partners for the above purposes. To learn how to exercise your right to opt-out, please see section 1 of this Disclosure.

If we have actual knowledge that you are under 16 years old, we will not sell your personal information without affirmative authorization.