PRIVACY POLICY

Last Updated: June 27, 2025

This Privacy Policy (“Policy”) explains how Tilting Point Media LLC and Tilting Point Media S.L. (collectively referred to as “Tilting Point”, “we”, “us”, or “our” in this Policy) collects, stores, uses, or otherwise processes personal data of end users of our Services as defined below (referred to as “you” or “your” in this Policy), and what rights you have if we are processing your personal data. If you are playing one of our Apple Arcade Games, please review our Apple Arcade privacy policy, which apply specifically to our Apple Arcade games.

In this Policy, “Services“ refers to our Games, Websites, and any related services or properties we directly control. “Games” refers to online games or applications that we own and operate. Some of the games or applications available through our page on various platform stores are nonetheless managed directly by their respective developers. For such games or applications the developer and not Tilting Point controls personal data processing and those games are subject to their respective developers’ privacy policies, not Tilting Point’s. Please review the list of Games that are governed by this Policy. “Websites” refers to websites and other online properties we control that link to this Policy, including www.tiltingpoint.com. 

For important information regarding our practices related to children’s information, please see the Section below titled “Children’s Privacy” and our Children’s Privacy Policy .

We use the term “your data” or “personal data” to refer to data that relates to you as an identified or identifiable individual, including non-personal data that can be combined with other data to potentially identify you. You must read and accept this Policy before accessing or using our Services so that you are aware of how and why we may use data relating to you. In addition to this Policy, we encourage you to carefully review our Terms of Service or other terms and conditions that you enter into, which govern your use of our Services.

1. DATA CONTROLLER

By “data controller”, we mean an entity that determines how and why personal data is processed. With regard to the personal data we process as described in this Policy, we are the data controller. While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to Section 6 (WHO DO WE SHARE YOUR DATA WITH?)., which govern your use of our Services.

2. CONTACT INFORMATION

In matters related to this Policy, you can reach us by email at privacy@tiltingpoint.com. You can also reach us by mail at Tilting Point Media LLC, 360 NW 27th Street, Miami, FL 33127, USA.

3. WHY DO WE PROCESS YOUR DATA AND ON WHAT BASIS?

3.1 LEGAL BASIS

When we process or collect your data, we ensure that we have a legal basis to do so. Below, you can find examples of the different purposes for which we process your data and the legal basis we have for each of those reasons:

To perform our contract with you (e.g. the license we grant to you to use our Services in accordance with the Terms of Service or other legal agreement that applies to the Services you use), we may process your data as necessary to:

• create and maintain an account for you in our Games or other Services where applicable,
• enable you to play our Games or use our other Services, and provide their correct versions (for example, selecting an appropriate language version for you),
• verify your purchases or other transactions in our Games or other Services,
• where available, enable you to communicate with other users in our Games or other Services (for example, by providing chat, forums, or other similar features),
• where available, provide social features (for example, clans, matchmaking, or leaderboards) or events in our Games or other Services, 
• personalize your gameplay experience and provide you with offers and rewards in our Games based on your activity in those Games,
• where available, enable you to save and synch your gameplay across multiple devices (for example, by giving you the option to connect a third-party account with our Games for that purpose),
• send you service-related communications (for example, technical notices, security alerts, or administrative messages), or
• handle your support requests or otherwise manage our relationship with you.

Based on our legitimate interest to constantly improve our Services, we may process your data to:

• operate and maintain our Services (for example, by making sure our Services are secure and function as intended),
• troubleshoot or debug any bugs, errors, or other issues in our Services,
• measure and analyze the use of our Services or data we collect through our Services (for example, to discover trends or other insights or to inform our operations),
• create data that is not identifiable to you for statistical or research purposes (for example, anonymized or aggregate data),
• conduct surveys or other research to learn more about our users,
• improve our current Services or develop new Services,
• keep track of installations of our Games (including the source of each install),
• measure, analyze, and improve the effectiveness of our advertising (including our advertising outside of our Services), or
• send you communications about offers, rewards, events, or other news related to our Services.

Based on our legitimate interest to make sure our Services are a fair and safe environment for all users, and to maintain security for our Services and business, we may process your data to:

• moderate and monitor the use of our Games or other Services (including any messages sent through the Services), either automatically or manually,
• ensure that our Terms of Service and other terms and conditions are followed,
• detect, investigate, or prevent fraud or fraudulent or otherwise unauthorized behavior,
• audit our operations or processes (for example, to verify that they function as intended and according to regulatory or contractual requirements), or
• establish, exercise, or defend our legal rights to the extent permitted by applicable laws and regulations.

Depending on how you interact with us, including the Games you choose to play, we may process your data based upon your consent to:

• send you newsletters or other similar communications if you have subscribed to them (for example, through a subscription form on our Websites or link in our Games),
• ask our advertising partners to show or not show our ads to you based on your activity (including by limiting the number of times you see our ads),
• place cookies on your device when you use the Websites (through our cookie consent manager/banner), or
• for other purposes explained to you when we ask for your consent.

Finally, we may process your data as necessary to:

• comply with legal obligations which apply to us (including accounting and tax requirements and requirements to provide information to competent authorities upon due request), or
• protect your vital interests or the vital interests of another person.

In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.

3.2 ADVERTISING

Advertising is one of the tools that helps fund our Services and enables us to make our Games available free of charge. In some of our Games, we may show our own ads and also ads from third parties. We also advertise our Games outside of our Services on third-party properties such as websites or applications. This section provides more information on how we may use your data for advertising purposes, and how you can control the use of your data for these purposes. 

Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses or other identifiers. An “Advertising ID” is an alphanumeric string of digits provided by the operating system of your mobile device (e.g. your phone or tablet). It is consistent across applications from different publishers. The Advertising ID is known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices. Advertising IDs are used for interest-based advertising and other advertising related purposes. You can control the extent to which your Advertising ID is used for these purposes. Using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising ID. For example, you can “limit ad tracking” on iOS devices or “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them as you prefer on each of your devices individually. It may take some time for your updated settings to take effect. 

Please consider that resetting or limiting the use of your Advertising ID will not stop you from seeing ads or necessarily reduce the number of ads you see, but the ads you see may be less relevant to you and will not be served based on your personal data.

When you see ads in our Games, we may share your personal data, including your Advertising ID and IP address, with our advertising partners. Depending on your consent settings in the relevant Game, this information may be used by our advertising partners to deliver personalized ads. Our advertising partners also collect non-personal information directly from our Games through technologies such as software development kits (SDKs) which is described in more detail below in Section 3.4 (SOFTWARE DEVELOPMENT KITS (SDKS) IN OUR GAMES). In each case, they may use such data for a number of purposes, including to display or deliver ads in our Games, track the success of advertising campaigns, limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID). For more information, please refer to the privacy policies of our advertising partners listed here.

When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID, have determined that you may be interested in our Services. When ad-networks use your Advertising ID in these ways, they do so based on their respective privacy policies or notices. 

Ad networks may also use your data to:

• limit the number of times you see our ads,
• inform users who have previously played our Games about new content, updates, or other news related to those Games, or
• refrain from showing our ads to users who already play the Game being advertised.

For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as total views, clicks, or installs generated by an ad. Measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as web beacons inserted into ads. This data is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.

You can opt out of interest-based advertisements from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), the Digital Advertising Alliance (https://optout.aboutads.info), or the European Interactive Digital Advertising Alliance (
https://youronlinechoices.eu/

You may also opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app and selecting your opt-out choices.

Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies.

Many of the opt-out preferences described in this section and elsewhere in this Policy must be set on each device and/or browser for which you want them to apply. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

3.3. COOKIES AND SIMILAR TECHNOLOGIES ON OUR WEBSITE

Like most websites today, our Websites may use cookies or similar technologies (for example, local shared objects or web beacons). A “cookie” is a small file your browser stores when told to do so by a website. Cookies can be set by either the website you visit (“first-party cookies”) or a third party involved in providing content, functionality, or services such as analytics or advertising for the website you visit (“third-party cookies”). Cookies are typically used to identify or “remember” your device, for example to enable functionality, facilitate audience measurement, improve performance, or store your preferences.  “Web beacons” (also known as pixel tags or clear GIFs) are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, often to compile statistics about usage of websites and the success of marketing campaigns.

As explained in the cookie banner seen when you first visit the Websites, we may only collect essential (necessary to enable functionality of the Website) and analytical (useful to improve our Websites by using information on its usage) cookies.

Using your browser or device settings or making a choice through our cookie banner, you can control the use of cookies, for example by disabling some or all cookies or configuring your browser or device to notify you when cookies are being set. However, please consider that disabling essential cookies may affect your ability to use the Services.

For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Services currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com

3.4. Software Development Kits (SDKs) In Our Games

In our Games, we may use software tools and programs such as software development kits, or SDKs. SDKs help us build and run the Games, and also allow us and our third-party service providers and advertising partners to collect data when a user interacts with a Game.

We use the following categories of SDKs in our Games:

• Game development SDKs, which provide us with the tools to create and run our Games on various mobile platforms. These SDKs may be operated by us or by a third party service provider, and may collect limited data about users such as device information or network details in order to operate and run our Games and for other business purposes like debugging.
  
• Analytics SDKs, which collect data such as device information (i.e., model, operating system, IP address) and details about how users interact with our Games, such as session length, access times, gameplay and usage statistics, and other engagement information. We and our third party service providers use analytics SDKs to monitor the performance of our Games, to troubleshoot problems with our Games, to analyze which parts of our Games are most popular, and for other monitoring, research, and development purposes.
  
• Advertising SDKs, which help us display ads within our Games and monitor how users interact with those ads, including by collecting data such as device information, general location information, and details about how users interact with ads displayed in our Games (such as length of time an ad was displayed, any clicks or other interaction with an ad, details about ad content and where it was served, and the success of a campaign). Our third party advertising partners may collect this data and combine it with information that they collect over time from the Games and from other sites, games, and services, and use it for the advertising purposes described above in Section 3.2 (ADVERTISING).
  

For more information about opting out of the collection of your data for commercial advertising purposes, please see
Section 3.2 (ADVERTISING) and Section 9 (YOUR PRIVACY RIGHTS).

4. WHAT DATA DO WE PROCESS?

We may process the following data relating to you:

• your name, email address, or other contact information if you have provided them to us (for example, when registering an account or subscribing to our communications),
• online identifiers such as your in-game alias, IP address, internal identifiers we assign to your account, or hardware or operating system based identifiers including your Advertising ID or device ID,
• technical information about the device you use to play our Games or use our other Services (for example, information about its type, model, manufacturer, operating system, language, display, processor, or memory),
• your coarse location (for example, country, state, or city), inferred from your IP address,
• information about your use of the Services (for example, information about your progress in our Games, your visits to our Websites, or your interactions with ads in our Games),
• information about your interactions with our ads outside of the Services (for example, on third-party websites or applications), including information on how you were referred to our Games or other Services,
• crash logs or other information related to bugs, errors, or other issues in our Services,
• inferences we make based on your activity in our Services,
• messages or other communications you send to us or through the Services (for example, your chat messages in our Games or emails you send to our support team),
• if you choose to connect a third-party account (for example, a social media account) with our Services, information we receive from the third-party account provider (for example, an account name, identifier, or email address to enable cross-device gameplay or a profile name, picture, or friends’ information to provide social features),
• if you make purchases in our Games, information we receive from third-party payment service providers to validate those purchases (but not your actual payment information such as credit card numbers),
• if you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so (for example, information about your background or experience with our Games),
• any other information you choose to submit to us through our Services or otherwise, and
• with your consent, other information explained to you when asking for your consent.

We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.

We may at times receive, or process personal information to create deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.

5. WHERE DO WE COLLECT YOUR DATA FROM?

We may collect data relating to you from the following sources:

• directly from you when you submit it to us (for example, when registering an account with us, subscribing to our communications, sending support enquiries to us, or responding to our surveys),
• directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services (for example, on third-party websites or applications), including through cookies or similar technologies or software development kits (SDKs),
• from our advertising partners involved in the delivery and measurement of ads when you interact with third-party ads in our Games or Tilting Point’s  ads outside of our Services (for example, on third-party websites or applications),
• from publicly available sources, such as social media accounts,
• if you choose to connect a third-party account (for example, a social media account or third party wallet) with our Services, from the third-party account provider,
• if you make purchases in our Services, from the third-party payment service provider involved in those transactions, or
• with your consent, from other sources explained to you when asking for your consent.

Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this Policy, depending on the Services you decide to use and your choices when using them. 

You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games, use your device settings to reset or limit the use of your Advertising ID, withhold consent for customized advertising, or disable some or all cookies from your browser settings.

6. WHO DO WE SHARE YOUR DATA WITH?

We may share your data with third parties to achieve the purposes described in this Policy. This may include sharing data with the following types of recipients:

• other companies in the Tilting Point group (which includes our parents and subsidiaries) or our Game or Services related affiliates, for example where they help us develop or operate our Games or other Services;
• persons or companies outside of the Tilting Point group that provide services to us and process data on our behalf when providing those services (for example, providers of hosting services, analytics services, services that add functionality to the Services, or other services that help us develop and operate our Services);
• other partners we work with while providing the Services (who may process your data independently of us), including advertising partners, IP licensors, and others listed here;Note that some of our advertising partners may use SDKs and the similar technologies described above in Section 3 (WHY DO WE PROCESS YOUR DATA AND ON WHAT BASIS?)to collect information about you (including online activity information and device information) over time across our Games and other websites and services, and use that information to serve ads that they think will interest you;
• prospective or actual buyers or investors (including their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring,
• competent courts of law or other government authorities where disclosure is necessary as a matter of applicable law or regulation,
• any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests, or
• with any other person or entity with your consent.

In addition, please consider that some information you submit or make available through the Services may be visible to other users of our Services. This typically applies to, for example, your public profile information in our Games (such as your in-game alias), your chat messages in our Games, and information used to provide social features such as clans or leaderboards. We encourage you to carefully consider what information you wish to share in this manner.

7. HOW LONG DO WE KEEP YOUR DATA?

We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. We may periodically delete or de-identify inactive accounts or other data in our Games or other Services. After the applicable retention period necessary for safe performance of Services, we will either delete or de-identify your data or, if neither deletion or de-identification is possible (for example, due to data being stored on a backup server), isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregate data).

8. HOW DO WE KEEP YOUR DATA SECURE?

We have adopted measures to provide your data a level of security appropriate for the degree of risk involved with the data processing activities described in this Policy. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ vary depending on the sensitivity of the data, but typically include, for example, encryption, pseudonymization of identifying data where feasible, physical and technological controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents.

9. YOUR RIGHTS

With respect to our processing of your data, you may:

• access, correct, or request the deletion of your data,
• request us to restrict our processing of your data,
• object to our use of your data for automated decision-making for direct marketing purposes,
• be informed about which third parties have received your data,
• receive a copy in machine-readable format of the personal data we have collected from you pursuant to this Policy,
• where technically feasible, request that your data is transmitted to another controller.
• know whether we are processing data about you and to obtain certain details about the data we have collected about you including, where applicable:
  • the categories of personal data collected;
  • the categories of sources from which we collected the personal data;
  • the purposes for which the personal data were collected;
  • the categories of personal data disclosed to third parties (if any);
  • the categories of personal information “sold” (if any); and
  • the categories of personal information shared for cross-context behavioral advertising or targeted advertising purposes,
• opt out of “sales,” “sharing” for purposes of cross-context behavioral advertising, or “targeted advertising” within the meaning of applicable privacy laws.

If our legal basis of processing your personal data is consent, then you may also withdraw your consent for processing such data at any time.

You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our products and services.

Please note, the rights listed above are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity. In addition, please note that all rights may not apply in your specific jurisdiction.

You may withdraw your consent or exercise your rights to opt out of “sales,” “sharing” for purposes of cross-context behavioral advertising, or “targeted advertising” in our Games by changing the applicable settings in the relevant Game, such as toggling “off” the use of your data for targeted advertising. To access your data in our Games or to request its correction or deletion, please contact us at privacy@tiltingpoint.com. To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message. 

At this time, because personal data collected on our Website through cookies and similar technologies is not used for targeted advertising (or otherwise sold or shared for purposes of cross-context behavioral advertising), if you broadcast the Global Privacy Control (GPC) signal to opt-out of such activities when visiting the Website, it will not impact how your personal information is disclosed. Further, due to technological limitations, broadcasting the GPC signal and any other browser settings that you set when visiting our Website will not apply to your activity in our Games, so any opt-out requests must be managed using the instructions above.

To exercise any of your rights, you may also contact us at privacy@tiltingpoint.com. 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.

Where permitted by law, you may also authorize an agent to submit the requests above on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and other information that we may need to verify the request, including evidence of valid permission for the authorized agent to act on your behalf.

While we will usually not do so, we reserve the right to charge you an appropriate fee for the exercise of your rights where permitted by applicable laws and regulations. If you believe that we have infringed your privacy rights, please contact us at privacy@tiltingpoint.com so we can try to resolve the issue. If you are an EU resident, you have the right to lodge a complaint with your local supervisory authority, and you may also reach our EU representative (Tilting Point Media S.L.) via mail (c/ Laforja, 12, pral 1a 08006, Barcelona, Spain).

If you wish to appeal a decision that we made about a request you submitted, you may submit your appeal by emailing us at  privacy@tiltingpoint.com. If you have concerns about the results of your appeal, depending on your state of residency, you have the ability to contact the Attorney General or Department of Justice in your state.

10. INTERNATIONAL TRANSFER

Tilting Point is a company based in the United States and, in order to provide you the Services, your data will be transferred to the US for processing and will be stored on Amazon Web Services. By using Tilting Point’s Services you acknowledge and consent to the processing of your data in the United States.

Since the United States is considered a country that does not ensure “an adequate level of protection,” according to the art. 45 of the General Data Protection Regulation (“GDPR”), Tilting Point relies on specific appropriate safeguards as well as derogations for safe transfer provided in the art. 46 and 49 of the GDPR. Namely, Tilting Point collects and transfers your data to the United States only due to the following circumstances: 1) because we entered into a contract with the Amazon Web Services or another service provider incorporating standard data protection clauses; 2) to perform a contract (providing you with the Services under our Terms of Service or other terms and conditions); 3) your consent.

11. CHILDREN’S PRIVACY

Tilting Point recognizes the importance of protecting children’s privacy. Please visit our Children’s Privacy Policy for more information about how we collect, use, and disclose personal information of individuals under the age of 16 in connection with certain of our Services, and the additional rights that parents and legal guardians may have in respect of their child’s information.

12. NOTE FOR CALIFORNIA RESIDENTS

This section applies only to California residents. It describes how we collect, use, and share personal information of California residents when we act as a “business” as defined under the California Consumer Privacy Act (”CCPA“), and their rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given under the CCPA.

12.1 Notice at Collection

Categories of Personal Information That We Collect, and the Purposes of Collection and Use. Depending on your use of our Services, the following categories of personal information may have been collected and disclosed in the preceding 12 months, as these categories are defined under the CCPA:

• Identifiers, such as name, email, IP address, device identifiers, Advertising ID, or other online identifiers.
• Characteristics of protected classifications under state or federal law, such as age.
• Commercial information, such as account details, information about your interaction with the Services, purchase history, marketing preferences, or communications.
• Internet or other electronic network activity information, such as he website you visited before browsing to the Services, pages, screens, or advertisements viewed, length of time spent on a page, screen, or advertisement, navigation paths between pages or screens, access times and duration of access, device information (such as computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution), other information regarding interactions with and activity on our Services and with advertisements, and general location information.
• Inferences drawn from personal information, including inferences about preferences, characteristics, predispositions, or behavior, such as purchase activity or gaming and ad viewing patterns.

These categories and the types of personal information we collect, use, and disclose are described more fully in Section 4 (WHAT DATA DO WE PROCESS?). The sources of our collection of personal information are described above in Section 5 (WHERE DO WE COLLECT YOUR DATA FROM?).

The business and commercial purposes for which we collect and use personal information are described in Section 3.2 (ADVERTISING)

To the extent that we may collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to provide the Services, detect security incidents and prevent fraud, or to verify and maintain the quality of the services). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.

Personal Information Disclosed for “Business Purposes,” “Sold,” or “Shared.” Section 6 (WHO DO WE SHARE YOUR DATA WITH?) describes the categories of third parties to whom we disclose personal information. Any of the categories listed above may be disclosed, or have been disclosed in the preceding 12 months, to these categories of third parties to operate our business or for the other business purposes described in this Policy.

Some of these categories may also be “sold” or “shared” within the meaning of the CCPA. The CCPA defines a “sale” of personal information to mean, for example, when a business sells, rents, releases, discloses, disseminates, makes available, transfers, or otherwise communicates orally, in writing, or by electronic or other means, personal information to a third party for monetary or other valuable consideration. When personal information is disclosed and used for purposes of cross-context behavioral advertising (whether or not for monetary or other valuable consideration), the CCPA calls this “sharing” personal information.

12.2 Opting-Out of Sales and Sharing

When you interact with our Games, and depending on your settings in the applicable Games, the following categories of personal information may be “sold” or “shared” to our third party service providers and the advertising partners listed  here.

• 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).

The purposes for these sales or shares are for the advertising purposes described in Section 3 (WHY DO WE PROCESS YOUR DATA AND ON WHAT BASIS?). We do not “sell” or “share” personal information of consumers under 16.

To opt-out of these “sales” or “shares,” you have several options:

• contact us at privacy@tiltingpoint.com
• decline to give consent to such sharing within a Game when you see a message asking for consent, if applicable; or
• if you initially opted-in for personalized ads within a Game, you may opt-out by going to the settings menu.

If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties.


At this time, because we already do not “sell” or “share” personal information through our Website using cookies and similar technologies, if you broadcast the Global Privacy Control (GPC) signal when visiting the Website it will not impact how your personal information is disclosed. Further, due to technological limitations, broadcasting the GPC signal and any other browser settings that you set when visiting our Website will not apply to your activity in our Games, so any opt-out requests must be managed using the instructions above.

I
You can also click here for more information: Your Privacy Choices.

13. NOTE FOR NEVADA RESIDENTS

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal data. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal data for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the top of this Policy.

14. CONTROLLING LANGUAGE

This Policy may be provided as a courtesy in multiple languages, however, the English language version of this Policy shall control in the event of any ambiguity between the English version and a version provided in another language.

15. CHANGES

We may update this Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also inform you of any changes by other means that are appropriate to the significance of the changes.

Configure Cookie Settings