Privacy Policy

This Privacy Policy describes:

• The ways we collect personal data about you and why we do so
• How we use your personal data, and
• The choices you have about your personal data.

This Privacy Policy applies to Simulations' games (including Countermove), store, sites and related services, which we here collectively call the Service. We may periodically update this Privacy Policy by posting a new version on countermove.ai. If we make any material changes, we will notify you as required under applicable law, including by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

CONTACT US

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the support features within each Simulations game, so we can reply to you more quickly. Alternatively, you may contact

Name of the controller: Simulations Limited
email: legal@countermove.ai

THE DATA WE COLLECT

The categories of personal data we collect depend on the Services you use, and the requirements of applicable law.

Data you provide us directly.

• Contact information (such as email address)
• Player name or password
• Profile information (such as profile photo)
• Your messages and other content you submit when you use the Service (agent prompts, agent names, agent avatars and player support tickets)
• Data you provide in connection with surveys, promotions, sweepstakes, competitions and other events
• Our payment service providers will collect your payment details in connection with any purchases you make through the Simulations' website that offer payments (such as Countermove)

Data we collect automatically.

• Data about your account and game progress, including in most cases an automatically created internal account ID
• Your IP address and mobile device identifiers (such as your device or advertising ID)
• Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier
• Data we collect with cookies and similar technologies (see more below)
• Approximate location data (as derived from IP address)
• Data about your use of the Service, such as gameplay data, purchases made and your interactions with other players inside the Service

You also have the option to create a Simulations ID on our gaming websites using your email address or other contact information.

Data we collect from our partners.

We also use third-party partners, such as social networking sites, data analytics providers and advertising networks to supplement information we have about you, such as:

• Data we receive if you link a third-party tool with the Service (such as Facebook, Instagram or TikTok in some markets)
• Demographic data (such as to determine the coarse location of your IP address)
• Data to fight fraud (such as refund abuse in games or click fraud in advertising)
• Data from platforms that the games run on or data from payment service providers (such as payment verification data)
• Data for advertising and analytics purposes (such as surveys), so we can provide you a better Service
• Data that you have made available to us from a third party service (such as Facebook, Instagram, LINE, WeChat or Kakao in some markets) via your privacy settings

WHY DO WE COLLECT YOUR DATA

We use your data for a variety of business purposes, such as:

To make the Service work.

To perform the contract, we process data necessary to

• Create accounts and allow you to play our games and use our Service
• Operate the Service
• Verify and confirm payments
• Provide and deliver products and services you request
• Send you Service-related communications

To make the Service more suitable for our players.

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

• Update and develop player profiles
• Develop and improve the Service and player experience
• Manage our relationship with you
• Provide social features as part of the Service
• Customize your Service experience
• Respond to your comments and questions and provide player support
• Provide you Simulations offers in the Service as well as in other websites and services (including by email)
• Send you related information, such as updates, security alerts, and support messages
• Enable you to communicate with other players

To show personalized advertisements.

To show you personalized advertisements in the Service and elsewhere (including email) we have a legitimate interest to process necessary data to

• Track the content you access in connection with the Service and your online behavior
• Deliver, target and improve our advertising and the Service

For information on how to opt-out from personalized advertisements, see section 'Your Rights and Options' below.

To keep the Service safe and fair.

Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy; Terms of Service.

In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

• Analyze and monitor use of the Service and its social features
• Moderate game logs either automatically or manually
• Take action against fraudulent or misbehaving players

To analyze, profile, and segment.

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

With your consent.

With your consent, we may process your data for additional purposes.

We may also collect and use your device identifiers to display and personalize in-game ads and serve behaviorally targeted advertising as explained below. Where applicable, we may collect your advertising identifier (IDFA, GAID), vendor identifier, IP address, device ID and other device identifiers (country, os version, device model, client version) for these purposes. Under applicable privacy laws, including the General Data Protection Regulation (GDPR), we are required to ask your consent to do so.

This data is shared with your consent so that our ad partners can deliver the right ad and optimize the ad content to make sure you don't see the same ad multiple times. We share your device identifiers with selected partners for such ad delivery and personalization.

You can manage your consent in the game settings and limit ad tracking in your device settings. Please note that opt-outs are specific to each browser and device and it may take a little bit of time before your opt-out will take effect.

For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS).

The partners operate the ad network and mediation platform, as well as facilitate and participate in ad inventory bidding. The partners may also use the device identifiers for fraud detection purposes based on their legitimate interest. For more information, please check the partners' privacy policies here: /resources/third-parties.

WHO CAN SEE YOUR DATA

Apart from Simulations, your data can be accessed by others in the following situations:

Other players and users.

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

Our service providers.

Simulations has vendors who help us to provide the Service. These vendors process your data only at and according to Simulations´s instructions to provide the Service, and perform tasks such as hosting, player support, advertising, analytics and fraud prevention.

Other companies and public authorities.

In order to verify payments (with payment providers such as Stripe) and combat fraud and illegal activity, we may process and disclose data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

Advertising and Social Media partners.

The Service includes features from our partners, such as social media interaction tools, functionalities through application programming interfaces (APIs) or software development kits (SDKs) and in-game advertising. A list of these partners is available at /resources/third-parties. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

These partners may access data regarding your activities and your device (such as your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share data we have collected about you with third-party advertising partners. These advertising partners may use this data (and similar data collected from other services) for purposes of delivering targeted advertisements to you when you visit third-party services within their networks. These partners may operate under their own privacy policies. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising." If you prefer not to share your personal data with third-party advertising partners, you may follow the instructions in "Your Rights and Options" below.

INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that we may use include standard contractual clauses approved by EU Commission and other lawful safeguards.

YOUR RIGHTS AND OPTIONS

Opt out of marketing emails and other direct marketing.

Where allowed under applicable laws, Simulations may send you marketing communications based on the existing customer relationship.

You may opt out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications, or by changing your in-game settings. The updated settings may not be effective immediately. Note that you may still continue to receive non-promotional communications from us, such as communications regarding the Service or updates to our Terms of Service or this Privacy Policy or transactional information e.g. relating to your purchases on the Service.

Push Notifications

We may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.

Opt-out of targeted advertising.

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and turning off "Allow Apps to Request to Track" or selecting "Limit Ad Tracking" (Apple iOS) or "Opt-out of Interest Based Ads" (Android). For more information, see also: /resources/third-parties.

You can also opt out from personalized in-game offers through the options provided in the game settings (where applicable).

Access the personal data we hold about you.

If you request, we will provide you a copy of your personal data in an electronic format.

Your other rights.

You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent.

We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may also contact your local data protection authority within the European Economic Area, Switzerland or UK for unresolved complaints.

If you wish to exercise any of your data subject rights described above, please use the support options described in "Contact Us" above. We will respond to all requests in accordance with applicable laws. To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request, such as by requesting you provide us a purchase receipt or other account information, asking you to link your email address with your game account (for example through Countermove ID), or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent's contact information to our customer support staff, as required by applicable law.

You have the right not to receive discriminatory treatment as a result of your exercise of these rights.

COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. Cookies and similar technologies allow us and our partners to store their preferences and track your activities within the Service. Note that our partners may operate under their own privacy policies.

We and our partners collect and store information about users' interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. We do so in order to

• detect and prevent fraud;
• improve the Service;
• allow users to use the Service on one device and pick up seamlessly where they left off on another device;
• analytics, personalization and attribution;
• limit the number of times a user is shown the same advertisement, across all known or inferred devices; and/or
• provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices.

You can disable cookies in your browser settings, but some parts of the Service may then not function properly. Here are links to some popular browsers where you can adjust your cookie and web data settings:

• Apple Safari
• Google Chrome
• Microsoft Edge
• Mozilla Firefox

For display advertising on the Web, you can also adjust your browser settings to limit certain tracking by means of cookies, and by visiting the following sites:

http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.

On some of our websites, we use third party analytics and telemetry providers and certain marketing providers for the above purposes. Where applicable, we ask for your consent on the site.

Google Analytics for visitor and usage analytics

Google Ads for ad targeting, analytics and reporting

Facebook Pixel for marketing

Mixpanel for analytics

Please note that above 3rd parties are not necessarily being used at all sites, or on all market areas. For further information (including how to opt out), please visit /resources/third-parties.

HOW DO WE PROTECT YOUR DATA

Security Safeguards.

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Data retention.

We retain your data for as long as your account is active or as needed to provide you the Service. We may for example periodically de-identify unused game accounts, and we may regularly review and de-identify unnecessary data.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

CHILDREN

Protecting children's privacy online is very important to us. Generally, our Services are not directed to children, and the Services do not knowingly collect personal data from children.

If you are a parent or guardian and wish to review personal data collected from your child, or have that information modified or deleted, you may contact us as described above. If we become aware that a child has provided us with personal data contrary to the above, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the child's account and/or revert them to the underage experience, as applicable.

DISCLOSURE FOR CALIFORNIA RESIDENTS

The following section applies to only to residents of California.

1) DATA COLLECTION

The categories of personal data we have collected in the preceding 12 months, and the sources of said data, are described in the section "THE DATA WE COLLECT".

2) DATA USE

The business or commercial purposes for collecting your personal data are described in the section "WHY DO WE COLLECT YOUR DATA" .

3) DATA DISCLOSURE AND/OR SALE

We do not "sell" your personal data with third parties as most people would understand that term. However, we may share your cookie information and advertising identifiers with our third-party advertising platforms to deliver interest-based advertisements, attribute installs and optimize campaign performance. To the extent that practice is considered a "sale" under the CCPA, you may opt out of said sharing by following the steps described in "Opt-out of targeted advertising".

We do not have actual knowledge of any sale of personal data of minors under 16 years of age, as the term "sale" is defined under the CCPA.

In the preceding 12 months, we have disclosed the following categories of personal data as part of our Services:

In addition to the sharing described above, we may share any information we collect about you with our affiliates, to protect us or others, or in the event of a merger, sale, or other asset transfer. See the section "WHO CAN SEE YOUR DATA" for more information.

4) YOUR RIGHTS

Your rights under California law are described in the section "Your Rights and Options".

DISCLOSURE FOR BRAZIL

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime. In the case of children younger than 13 years old, specific and prominent consent must be given by a parent or person responsible for the child.