Privacy Policy

(Last Updated: March 14, 2023)

We respect the privacy rights of our customers and protect the personal information collected, stored and used in connection with our products, services and websites. Your privacy is important to us. To further this commitment, we have adopted this Privacy Policy to guide you on how we collect, store, and use the information you may provide to us. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

1. Protecting Your Privacy

This Privacy Policy applies to any Pewty game, website, application, service or tool (collectively, our “Services”).

We are committed to protecting the privacy of all people who use our Services. Being a Franch company, we comply with EU General Data Protection Regulation (“GDPR”) and follow the privacy principles that are a part of the Privacy Act. Additionally, we seek to comply with relevant laws from the United States of America, including: the federal Children’s Online Privacy Protection Act (“COPPA”), the California Consumer Privacy Act of 2018 (“CCPA”) and the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 (“CAN-SPAM”), which covers the transmission of commercial email messages with the primary purpose of advertising or promoting a product. For purposes of this Privacy Policy and GDPR, Pewty is the data Controller with regard to any data we collect from you, unless otherwise specified. For individuals located in Brazil, we also seek to follow the Lei Geral de Proteção de Dados (commonly referred to as the “LGPD”).

Disclosure to Residents of California: In our efforts to comply with applicable laws, we ask and advise that California residents review the CCPA Disclosure at Section 12 of this Privacy Policy. Although we do not sell user data, we will provide notice if at any time those circumstances change.

Disclosure to Residents of Brazil: The LGPD grants residents of Brazil certain rights about the processing of their personal information and we ask and advise that residents of Brazil review the Additional Rights at Section 9 of this Privacy Policy.

Learn more: Protecting Your Privacy

2. What Personal Information Do We Collect?

Personal information is information that identifies you and that may be used to contact you online or offline. We collect personal information from you on a voluntary basis as described below. Our primary goals in collecting and using personal information is to create your account, provide Services to you, improve our Services, contact you, conduct research and create reports for internal use and for use with our partners.

Learn more: What personal information do we collect?

3. How Do We Use Your Information?

We use your personal information to provide and improve our Services, provide you with a personalized experience on our Sites, contact you about your account and our Services, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities.

Learn More: How Do We Use Your Information?

4. Who Do We Share Your Information With?

We do not share your personal information except as approved with your consent or as described below. We do not sell or rent your personally identifiable information to any third party, although non-personally identifiable information may be used to assist advertisers in targeting their services to specific user demographics. For example, we may provide third party advertisers with the aggregate number of males of a certain age in a specific country who are playing one of our Games.

• We share statistics of each user’s activities and data within reports that are used internally and externally by our publishing and distribution partners to analyze our Games, their features and performance.

• With your consent, for example, when you agree to our sharing your information with third parties and advertising networks for their own marketing purposes subject to their separate privacy policies.

• We may release your information as permitted by law or when we believe that release is appropriate to comply with applicable law; enforce or apply our rights; or protect the rights, property, or safety of use or our uses or others. This includes exchanging information with other companies and organizations for fraud protection.

• We may share your information in connection with any merger, sale of our assets, or financing or acquisition of all or a portion of our business to another company.

• We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.

5. How Long Do We Keep Your Personal Information?

We retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our Terms of Use, end user license agreements, and other contracts in place with third parties, including but not limited to our third party service providers and independent data controllers. Upon your request to remove your data, we will do our best to remove such data immediately, and in no event will we retain any data requested for removal more than thirty (30) business days after the date of the request.

6. Is My Information Secure?

The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect your information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

All gameplay services provided to you by Pewty are hosted using various Amazon Web Services (AWS) or Scaleway Services. AWS is a global leader in cloud technology and has robust data protection, privacy policies and processes in place. For more information, see https://aws.amazon.com/security/, https://aws.amazon.com/compliance/data-privacy-faq/ and https://www.scaleway.com/en/privacy-policy/.

7. Does My Information Go Across Borders?

We use third party servers in France to host some or all of our Games, information and archives. Therefore, your personal information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information. Our third parties have executed or provided to us adequate safeguards in the form of our standard Data Protection Addendum to our agreements with those third parties, which we can provide to you upon your request by contacting contact@pewty.fr.

Where you have the option to withdraw consent to opt out of any collection where your data is transferred across borders, you may do so. The transfer of such data is typically for the purpose of providing our Services to you, as specified above. Consequently, any request to delete or modify such personal information may result in the termination or interruption of our Services with respect to your usage of such Services.

8. Is Sensitive Information Collected?

We do not ask you to provide any “sensitive information” as a requirement to use our Sites or any of our Games. “Sensitive Information” means any personal information related to your health or sex life, genetic or biometric data, race, ethnicity, political views, religion, professional status, philosophical view, and trade or union affiliation. Sensitive Information that you disclose to “everyone” on a discussion forum or through a social networking site in connection with a Game may be collected and held by us in accordance with this Privacy Policy. We do not use or share Sensitive Information with third parties. Please contact us if you have any questions or concerns about any Sensitive Information that you may have disclosed to us or to other users during your use of a Game that we may have collected. We do collect non-personally identifiable information regarding Game usage, including but not limited to, the top country, city and language by aggregate usage as provided by the social networking sites.

9. Your rights to access, control, and correct your personal information

You have the right to see what personally identifiable information we hold about you if you request it. If your request is particularly complex or requires detailed searching of our records, there may be a cost to you in order for us to provide you with this information. We will aim to respond to any requests within thirty (30) days of receipt.

10. What Happens When I Remove A Game or Unsubscribe From A Newsletter?

You have the ability to opt-out of: receiving information and marketing emails from us; publishing your recent Game activity to your SNS page; bookmarking or displaying the Game page to others, and of course the ability to delete our Game and rescind any permissions required to operate such Game, at any time.

It is our responsibility to keep accurate, complete and up-to-date records, so any changes you make in a Game regarding your personal information will go into effect as quickly as technically possible. We reserve the right to retain the non-personally identifiable data collected during your use of the Game.

We have the right, pursuant to our Terms of Use, to delete messages, content and accounts in whole or in part, at our discretion, that we find offensive to the general public, uses profanity, causes complaints from other users, is not suitable for a general audience or infringes the intellectual property rights of any third party. For example, talk of drugs, alcohol, violence, strong language, gambling, crude humor, sexual themes or those suggestive in nature is prohibited.

11. Children’s Privacy

We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our Services. Some of the features on our Sites and Games are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features.

When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:

• Notifying parents or guardians about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;

• In accordance with applicable law, obtaining consent from a parent or guardian for the collection of personal information from their children, or for sending information about our products and Services directly to their children; and

• Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity.

If you are a parent or guardian and wish to review or change the information we may have about your child, email us at contact@pewty.fr.

12. California Residents: Your California Privacy Rights

Under the laws of the State of California (USA), California Residents who have an established business relationship with us may choose to opt out of our disclosure of personal information about them to third parties for direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email contact@pewty.fr.

In September 2013, California enacted amendments to the California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) which require operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the websites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and sites has not yet been widely adopted. Currently, our computer system does not support, and cannot act on DNT signal headers that we may receive; accordingly, the choices that we provide you concerning our collection and use of personally identifiable information will continue to operate as described in this Policy. For information about Do Not Track, please visit: www.allaboutdnt.org

Pewty also complies with the California Consumer Privacy Act (CCPA) that was enacted in 2018 and effective as of January 1, 2020. The CCPA secures specific privacy rights for California consumers.

How Do We Use Your Information?

In addition to the details provided in 3. How Do We Use Your Information?, Californian residents can refer to the table below

Category    Data Collected  Reason for Collection   Has Information been “Sold” to 3rd Party In the preceding twelve (12) months?

Identifiers     Internet protocol address (truncated)   Analytics (by coarse location), fraud detection, personalised ads, marketing campaign performance measurement   Yes (personalised ads)

   Advertising identifier  Personalised ads, marketing campaign performance measurement    Yes (personalised ads)

   MAC address     Personalised ads, marketing campaign performance measurement    Yes (personalised ads)

   Email Address   Customer support, opt in user surveys   No

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).    None Collected      No

Protected classification characteristics under California or federal law.   None Collected      No

Commercial information.     Game install details, In App Purchase history   Analytics, personalised ads, marketing campaign performance measurement, customer support and fraud detection   Yes (personalised ads)

Biometric information.  None Collected      No

Internet or other similar network activity.     Game install details, In App Purchase history, Session events   Analytics   No

   Advertising events (clicks, ad engagement)  Personalised ads    Yes

Geolocation data.   Coarse location (inferred from Internet truncated protocol address)     Analytics, fraud detection.     No

Sensory data.   None Collected      No

Professional or employment-related information.     None Collected      No

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).  None Collected      No

Inferences drawn from other personal information.   None Collected      No

Personal information does not include the following:

• Publicly available information from government records.

• De-identified or aggregated consumer information.

• Information excluded from the CCPA’s scope, like:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

•  Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We may obtain the categories of personal information listed above from the following sources:

• Directly from our users. For example, from users who engage us for customer support or to provide customer feedback.

• Indirectly from our users. For example, through information we collect from our users in the course of providing customer support to them.

• Directly and indirectly from activity on our Sites or in our Games. For example, from APIs and cookies (described above) embedded in our Sites or Games to measure Game metrics and progress, play time per level, and other information related to improving ourServices.

• From third-parties that interact with us in connection with the Services we perform. For example, from third party analytics or anti-cheat providers, or to ad mediators for the purpose of providing personalized advertising and marketing customized to you.

All such personal information is used as otherwise described in this Privacy Policy.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Identifiers, commercial information, internet or other similar network activity, and geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

   Our affiliates.

   Service providers.

   Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or Services we provide to you.

   Our vendors.

Your Rights To Access, And Control Your Personal Information

You have the right to opt out of the sale of personal information. Please follow the instructions in Controlling Personalised Ads.

We recommend submitting data access requests using methods described in 9. Your rights to access, control, and correct your personal information.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

13. Changes to the Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy, we will post those changes on this page and update the date at the top of the page. We will also notify changes on various channels we might have to reach you including push notifications (if available), our Facebook page, our Company Website, or via notification directly in our apps. The changes will be effective when posted. Please check this page on a regular basis so that you remain aware of what information we collect and how we use it.

14. Contacting Us

For enquiries regarding this Privacy Policy and personal information, please contact:

By Email:

Contact Us or contact@pewty.fr.