CRYSTALBORNE: HEROES OF FATE PRIVACY POLICY

Last Updated: December 10, 2019

“Arena of Stars,” “we,” “us,” or “our” refers to Arena of Stars LLC and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We provide this Privacy Policy to help you (“you” or “user”) understand how we collect, store, use, and manage information, including personal data, that you provide to us or we collect about you when you use or access our games, products, services, content, www.crystalborne.com, www.arenaofstars-online.com, and/or other domains or websites operated by us (the “Services”).

This Privacy Policy applies whenever you use our Services. Please read it carefully. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE ANY SERVICE.

AD IDENTIFIERS, COOKIES, AND SIMILAR TECHNOLOGIES

Ad identifiers are non-permanent identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. Cookies are small text files that are stored by your browser on your desktop computer or mobile device.

When you access the Service, we collect certain technical information in order to (i) analyze the usage of our sites and Service; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf, such as Google Analytics, will use Log Files and other tracking technologies to collect and analyze certain types of technical information over time and across different websites following your use of the Service, including cookies, WiFi information, IP addresses, geo-location, 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, Service state and the date and time of activity on our Services, and other similar information. In some cases, we will associate this information with your user ID number for our internal use. Our Service currently does not respond to “Do Not Track” (DNT) settings in your web browser and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy. For further details regarding DNT, visit donottrack.us.

We also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to prevent fraud, remember your in-Service preferences and speed up load times.

You can choose to prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under "privacy" or "ads" in your device's settings.

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit adobe.com and make changes at the privacy settings panel. If you disable cookies, you may lose some of the features and functionality of playing our Services, as cookies are necessary to track and enhance your Service activities. Please note that companies delivering advertisements in our Services or on our websites may also use cookies or other technologies, and those practices are subject to their own policies.

We also use Google Analytics, who uses cookies to help the website analyze how users use the Service and enhance your experience when you use the Service. For more information on how Google uses this data when you visit our Site or use our Services, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

The NAI (Network Advertising Initiative) allows for the central opting out of all its members’ cookies from a single opt-out page. If you prefer not to receive relevant advertising on web pages, please click on the following link: networkadvertising.org/choices/. If you delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice.

INFORMATION AND DATA WE COLLECT ABOUT YOU

(a) Information we collect from you directly

When you interact with the Service, at www.crystalborne.com, www.arenaofstars-online.com, any other Arena of Stars – owned website, or download the Service from a third-party app store, we will collect and store information from you directly as described below, to the extent it is available to us. You can register with us by using Facebook Connect or other application authentication options to create an account or profile within the Service. In a typical registration flow we may collect the following information from you: age; e-mail address; password. We may also offer you the option to complete a user profile that is visible to other Service users. Your user profile may include: a profile image; one or more Service username(s); and a user ID number that is created by us and used to identify your profile.

If you access the Service on your mobile telephone or other mobile device, including iPads and tablets, we collect the following information, to the extent it is available: device advertiser ID; MAC Address; WiFi information; IP Address; and Geo-location.

We will also collect the following information about you, to the extent it is available: name you have associated with your device; device type; telephone number; country and geo-location; user name, character name; e-mail address.

When you ask for assistance from our Customer Support team, we will collect and store: your name and e-mail address; information about your activity on the Service; your user name or ID number; and any correspondence connected to the assistance provided to you.

We will create and assign to your device an identifier that is similar to an account number.

We also collect pseudonymous usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files (“Log Files“), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number(s). For more information on how we utilize cookies and other tracking technologies, please refer to "Ad identifiers, cookies, and similar technologies" below.

(b) Information we collect from other sources

We will collect or receive information from the following other sources (i) other Service users who choose to upload their email contacts; (ii) third party information providers such as digital advertising companies; and (iii) social networking sites.

We will use information collected from you in any one or more of the following ways:

If you have provided your e-mail address to us, we’ll use it to respond to (i) customer support inquiries, (ii) keep you informed of your in-Service activity, including comments from friends, notifications about in-Service status and requests, and (iii) provide you with details of our similar games or Services, unless you have asked us to stop sending you our marketing material or opted out from our electronic marketing communications.

We may use the information we hold about you to promote our Services in any one of the following ways:

We use information about you to try to make sure you only see marketing from us that might be of interest to you, including:

You can exercise choices over the direct marketing we send you in the following ways:

You should note that if you opt out of receiving interest based or targeted advertising, you may see advertising for our Services, but that advertising will not be targeted using your personal information.

We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by “opting in” to receive information from a third party that is participating in a sweepstakes or other promotion on one of our sites. If you do ask us to share your personal information with a third party for its marketing purposes, we will only share information in connection with that specific promotion, as we do not share information with any third party (other than our service providers) on a continual basis. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt in to such use when you provide personal information on one of our sites.

Your access to the Services will not be affected if you do not “opt in” to receive information from such third parties.

California Civil Code Section 1798.83 permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to: Customer Service c/o Arena of Stars LLC, 795 Folsom Street, Floor 1, San Francisco, CA 94107.

SHARING OF YOUR INFORMATION

Arena of Stars shares your personal data with our Affiliates including in the United States. Please be aware that the US and other jurisdictions may have a lower standard of data protection laws than your own jurisdiction. We will also share your personal data with third party recipients (i.e., parties other than our group of companies) including outside the European Economic Area, in for the following purposes:

YOUR RIGHTS AND HOW TO ACCESS, UPDATE, AND MANAGE YOUR PERSONAL INFORMATION

(a) Information we receive from a social networking site (“SNS”)

To manage the information Arena of Stars receives about you from an SNS where you use our Services, you will need to follow the instructions at that site for updating your information and changing your privacy settings. The privacy management tools for applications on Apple can be found at http://www.appleprivacywebsite.com. The privacy management tools for Google can be found at http://www.googleprivacywebsite.com. The privacy management tools for Amazon can be found at http://www.amazonprivacywebsite.com. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of each application.

Once Arena of Stars receives your information from an SNS, that information is stored and used by Arena of Stars in accordance with this Privacy Policy, and you may access and update that information as described below. Service or other accounts created with Arena of Stars are considered active until we receive a user request to delete them or deactivate them.

(b) Other methods of accessing or controlling your information

If you no longer want Arena of Stars to make active use of your information, you may send an e-mail to support@arenaofstars-online.com. Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and user ID number from which you access our Services (if applicable) in the body of the e-mail. If you do so, you will no longer have access to the game account or services associated with your account. Other steps you should take should you wish to delete your account include disassociating your Facebook account from our mobile games and deleting the game from your mobile device. Please note that if ask us to delete your account all your progress in the game and any unused virtual items will be lost and we may not be able to restore them in the future. We will respond to your request within thirty (30) days. Arena of Stars may use your information unless and until you send Arena of Stars such a request. Please note that your information, for example those records pertaining to payments or customer service matters, may be retained for legal and accounting purposes. If you have sent or posted content on the Service, we may not be able to delete it.

(c) Opting Out of Push & Local Notifications

When you install our apps on your mobile device you can choose to receive push notifications. Where you opt to receive push notifications, will send push notifications to your mobile device to provide Service updates and other relevant messages. You can turn off push notifications by visiting the "options" or "settings" page within the relevant Service. You may also receive local notifications. You can turn off local notifications by visiting the "options" or "settings" page within the relevant Service.

Specific Provisions for EU Individuals

For purposes of the European General Data Protection Regulation, the “data controller” of your personal information is Arena of Stars, LLC, 795 Folsom Street, Floor 1, San Francisco, CA 94107. Our data protection officer can be contacted at dataprotectionofficer@arenaofstars-online.com.

Deletion of your personal data. In some circumstances, you may request that we erase some of the personal data we hold about you. Should you wish to have your personal information deleted, please contact us at support@arenaofstars-online.com. When we delete any information, it will be deleted from our active databases but may remain in our archives. Please note, however, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form.

Access and portability. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us at support@arenaofstars-online.com and let us know that you wish to exercise your right of access and what information in particular you would like to receive. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person.

If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party.

Correction. You have the right to correct any personal data held about you that is inaccurate. Where you request correction, please explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required.

Restriction of processing to storage only. You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances, e.g. whilst we are considering whether it should be corrected or deleted or, based on your objection, whether we should permanently stop processing. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds for us to do so (e.g. for the defence of legal claims or for another’s protection).

Objection. You have the right to object to our processing of data about you other than where required to perform under the Terms of Use, e.g. in order to send you promotions and special offers marketing.

You also have the right to object to our processing of data about you by emailing us at support@arenaofstars-online.com in the following circumstances:

Lawful Bases for Processing

Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our games, customer services, and chat functionality;

Legal Obligation. This covers data used by us to comply with legal obligations, such as to maintain records relating to tax or to respond to valid legal requests for certain data;

Legitimate Interests. This covers data used by us for purposes that can be reasonably expected with your use of our Services and that we do not believe are harmful to your privacy, such as analytics to understand how our users navigate our websites and apps, to keep our websites and apps safe and secure, research and optimization of our games and other Services, to provide a more personalized experience, marketing and advertising; and

Consent. Where we process data based on your consent, we will ask for your explicit consent. You may withdraw consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.

While you can withdraw your consent or object to certain types of processing at any time in the ways described in this Privacy Policy, please note that if you play our games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not want us to collect any personal data about you at all, you should cease playing our games and stop using our Services.

Retention. We retain your personal data for the duration of your account, as long as reasonably necessary to provide you the services, and for such periods necessary to comply with the law.

In the event you request deletion of your personal data in accordance with the process explained above, we will delete it as specified above. Please note that we may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints. For example, we may retain records pertaining to payments or customer service matters. If you have sent or posted content on the Service, we may not be able to delete it.

International Transfers of your Personal Information. As you are contracting for the Services with Arena of Stars, which is a US company, any information you provide to us, or that we collect through your use of the Services that is necessary to provide you the Services, will be stored, processed, and transferred within, or to, the United States. As a result, your information could be accessed by foreign governmental authorities, or otherwise, in accordance with applicable local laws. Please be aware that the US and jurisdictions other than the one in which you are located will not have the same data protection laws as your own jurisdiction. Your personal data is also processed by staff or service providers operating outside the EEA in the United States, who work for us. If we transfer your information outside of your country of residence, we will protect that information as described in this Privacy Policy.

Complaints. In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at privacy@arenaofstars-online.com and we will endeavor to deal with your request. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

OUR POLICIES CONCERNING CHILDREN

Our Services (including websites, games, and applications) are not intended for children (aged 13 or such higher age as required by applicable law). We do not knowingly collect or solicit any personal data from children and we do not knowingly allow children to register for or use the Services. Children should not use our Services or send us any personal data about themselves at any time. In the event that we learn that we have inadvertently gathered personal data from children, we will take reasonable measures to promptly erase such information from our records. If you believe that we might have information from or about a child, please contact us.

CONTACT US

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to support@arenaofstars-online.com. We will seek to respond to any complaints within thirty (30) Days.

CHANGES TO OUR PRIVACY POLICY

If we decide to make material changes to our Privacy Policy, we will notify you and other users by placing a notice on www.arenaofstars-online.com or by sending you a notice to the e-mail address we have on file for you. We may supplement this process by placing notices in our Services and on other Arena of Stars websites. It is your responsibility to periodically check this privacy page for updates.

PRIVACY POLICIES OF LINKED SITES

Our Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of such websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly.