(Last Updated: October 2021 with effective date 21 October 2021)
The types of information we collect and how we collect it
Athena FZE collects the advertising identifier (Apple’s IDFA and Google’s advertiser ID), and a unique identifier for each user in our mobile games.
Athena FZE integrates many third party SDKs in to our services. These SDKs are used for advertising to our users, analyze service usage, enabling in-app purchases, or providing game services like achievements and leaderboards. We allow third party operators this collected solely for internal operations of the service as permitted by applicable rules and laws. This could include, but is not limited to, persistent advertising identifiers, geolocation information, and IP address. We encourage you to review the policies of the third party operators listed below.
Should a user explicitly provide it to us when prompted, we will collect email addresses of our users for our mailing list(s).
Some of our services require or allow a user to provide a screen name so they can be identified within the service.
We allow third parties to collect some anonymous information by which users cannot be identified. Non-personal information may include technical information about your device, such as your browser type, screen resolution, device type, language, type of operating system and geo location (only general location). Non-personal information is gathered by third party services while you are accessing the service. They are allowed to use this information to conduct research and analysis, but only for strictly limited purposes. We encourage you to review the policies of the third party operators listed below.
Internally, Athena FZE also reserves the right to collect anonymous information for research and analysis. This information is generic in nature and cannot be used to individually identify a user. This information is collected each time a user runs one of our services.
Service Specific Information
Some Athena FZE services allow users to send messages to each other while playing a game. These messages are then transmitted and store on Athena FZE controlled servers.
In order to support some services, Athena FZE may collect identifiers associated with a user’s account on social networks like Facebook or Twitter, or game services like Apple Game Center, Google Play Game Services, or Amazon Game Circle.
Additionally, we may also use a user’s profile picture from social networks or game services, but this will stay on the device and will not be transmitted to us.
What we do with the personal information we collect
Advertisers collect data regarding advertisement performance, user’s interaction with ads, our apps and user’s interests. Collected data may include user’s personal information in order to serve users ads and for the third parties’ legitimate business interests.
Athena FZE collects persistent identifiers in order to provide support for our services to our users. Additionally, Athena FZE uses persistent identifiers to send promotions regarding new products or updates to our users. If we keep track of persistent advertising identifiers, it allows us to only notify these users about new products that they will actually be interested in. We collect email addresses in many of our services so that we can notify interested users of upcoming releases and updates of our products and services. These emails always include a way to unsubscribe from receiving future emails. When a service asks for a username, it is used to visually identify that user to other users playing the game. Athena FZE prohibits any user under the age of 13 from providing individually identifiable information in their username or screen name. This includes, but is not limited to the user’s first name, last name, email address, and physical address.
What we do with the non-personal information we collect
Third party operators are allowed to collect and use non-personal information to conduct research and analysis, or to target advertisements, or other limited purposes. This information cannot be user to individually identify any user. We encourage you to review the policies of the third party operators listed below.
Similarly, Athena FZE also uses non-personal information to conduct research and analysis. We do this to improve our services in future updates or to gain knowledge about how our users our interacting with the service.
What we do with service specific information we collect
Each of our games that allow messaging other users provide an option for joining or creating publicly visible worlds/matches, or for playing only against other users known to the current user. Athena FZE prohibits any user under the age of 13 from joining or creating publicly visible worlds/matches in these services. Additionally, Athena FZE prohibits any user under the age of 13 from sharing personal or individually identifiable information while using the messaging functionality in these services.
If Athena FZE collects identifiers associated with a user’s account on social networks like Facebook or Twitter, or game services like Apple Game Center, Google Play Game Services, or Amazon Game Circle, then it is explicitly required for some feature in that service. For example, the identifier could be saved so that a user’s connections on the social network can see their high score or progress in the game. As stated elsewhere in this policy, you can contact us to have this information deleted for yourself or your child under the age of 13.
We understand the importance of protecting the privacy and safety of children using our services, as outlined by the Children’s Online Privacy Protection Act of 1998 (COPPA). Accordingly, we do not knowingly collect, use, or disclose personal information from children under 13.
When we determine that a service is directed and children under the age of 13, we will configure all of our internal systems such that no personal information will be collected, and configure all relevant third-party integrations appropriately such that no personal information will be collected for users of that service. For additional information, please refer to the privacy policies of our third party operators to understand what they are doing to further protect your child’s privacy.
Services that are determined to be targeted at children will still receive advertisements from our third-party operators, and promotions from Athena FZE using its internal systems. In this case the ads and promotions will not be targeted at specifically for users, but will be broadcast to all users of the service.
If you are a parent of a child under 13 years of age and you believe your child has provided us with personal information, please contact us using the information below and we will delete the information from our systems.
Disclosure of Personal information
The scenarios in which we will share your personal data are as follows:
We determine that it is required by law;
We have a good faith belief it is necessary to protect our rights or property;
We are participating in a merger, acquisition, liquidation, dissolution or sale of assets;
We have your consent; and
As described above in relation third-party operators collecting information from our services.
Under no other circumstances will Athena FZE share, sell, rent, or release your data.
We follow generally accepted industry standards and internal procedures to protect personal information submitted to us, both during transmission and once we receive it.
Advertising Networks: Athena FZE allows advertisements from the Third Party ad networks to be displayed in our services. Athena FZE makes commercially reasonable efforts to ensure that the third party ad networks are configured to comply with applicable privacy laws, and we reasonably believe this to be the case for each of them. Additionally, if we determine a service to be directed at children under the age of 13, we configure each of these ad networks to be compliant with the Children’s Online Privacy Protection Act of 1998 (COPPA).
The following is a list of the third party operators we currently use in our services, their contact information, and links to their privacy policies:
Apple, iAd, Game Center
Attn: Privacy Officer
11400 W. Olympic Blvd., 12th Floor
Los Angeles, CA 90064
849 High St.
Palo Alto, CA 94301
420 Taylor Street
San Francisco, California 94102
1601 Willow Road
Menlo Park, CA 94025
701 First Avenue
Sunnyvale, CA 94089
Google Play, AdMob, Google Play Game Services, Google Anayltics, Firebase Analytics
795 Folsom Street
San Francisco, California 94107
185 Clara Street,
San Francisco, CA 94107
100 1st Street, 25th floor,
San Francisco, California 94105
Specific Provisions for EU Individuals
Accessing and Correcting Your Personal Information. At any time, you may contact Athena FZE at the address provided in the “Contact Athena FZE Studios” section herein and request to access the personal data that Athena FZE holds about you. Athena FZE may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, then please provide Athena FZE with the necessary information to correct it.
Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.
Erasing or Restricting Access to Your Information. You may request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.
Transferring your Personal Data (Otherwise known as Your Right to Data Portability). You have the right to receive your personal data that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.
Right to Make Complaint: if you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
If you have any concerns about the way we process your personal data, you are welcome to contact our data protection officer at email@example.com or write to us at the address set forth in the “Contact Athena FZE Studios” section. We will look into your request and make good faith efforts to resolve any concern you may have.
Specific Provisions for California Consumers
These additional provisions for California consumers apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires “businesses” collecting or disclosing personal information to provide notice and a means to exercise those rights.
Right to Know and Right to Delete
For any of the personal information described above, you can request to know what personal information we collected, disclosed, used and sold, and request that we delete your personal information at any time.
To exercise your right to know and right to deletion, please submit a request by:
Emailing firstname.lastname@example.org with the subject line “California Rights Request.”
Or opening App Settings, select "Contact us", select "Account", select "How to delete my player account?"
We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.
Upon verification of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless retaining the information is necessary for us or our service providers to complete the transaction with you, detect security incidents or fraud, fixing errors, exercise free speech or another right provided by law, comply with legal obligations, or other internal and lawful uses.
Right to Opt Out of Sale
CCPA gives you a right to direct a business that sells your personal information to stop selling your personal information and to refrain from doing so in the future. We do not sell any of your personal information and will require our service providers not to sell your personal information.
You also have the right not to be discriminated against for exercising any of the rights listed above.
If you are a California resident seeking to exercise your rights under the CCPA or have any questions or concerns, please email us at email@example.com. In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.