California Notice


Effective November 1, 2023

Scope of Supplemental Notice

This additional California Notice (the "Notice") supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California ("consumers" or "you").

This Notice provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 ("CCPA").

Unless otherwise expressly stated, all terms in This Notice have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.

Collection and Use of Personal Information

When we use the term "personal information" in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

In the last 12 months, we have collected the following about consumers for the following purposes.

Category of Personal Information Categories of Sources Commercial or Business Purpose
Identifiers, such as Account Name, Device ID, Email Address, IP Address, etc.
  • Players
  • Players’ Devices
  • Data Services
  • Service Providers
  • Detecting/Protecting against security events
  • Internal analytics and reporting
  • Internal research
  • Customer service
  • Operate our business and games
  • Game mechanics or functionality
  • Facilitate players' social interactions
  • Debugging existing intended functionality
  • Product development/improvement
  • Maintaining and enhancing service
  • Auditing consumer interaction & transactions
  • Advertising
  • Direct marketing (phone, email, etc.)
  • Detecting/Protecting against security events
  • Player acquisition
California Customer Records (Cal. Civ. Code § 1798.80(e)) such as Address, Name, Telephone Number.
  • Players
  • Players’ Devices
  • Data Services
  • Service Providers
  • Social Network Services
  • Detecting/Protecting against security events
  • Internal analytics and reporting
  • Internal research
  • Customer service
  • Operate our business and games
  • Game mechanics or functionality
  • Facilitate players' social interactions
  • Debugging existing intended functionality
  • Product development/improvement
  • Maintaining and enhancing service
  • Auditing consumer interaction & transactions
  • Advertising
  • Direct marketing (phone, email, etc.)
  • Detecting/Protecting against security events
  • Player acquisition
Protected Classification Characteristics, such as age and gender.
  • Players
  • Players’ Devices
  • Data Services
  • Service Providers
  • Social Network Services
  • Detecting/Protecting against security events
  • Internal analytics and reporting
  • Internal research
  • Customer service
  • Operate our business and games
  • Game mechanics or functionality
  • Facilitate players' social interactions
  • Debugging existing intended functionality
  • Product development/improvement
  • Maintaining and enhancing service
  • Auditing consumer interaction & transactions
  • Advertising
  • Direct marketing (phone, email, etc.)
Commercial Information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Players
  • Players’ Devices
  • Data Services
  • Service Providers
  • Social Network Services
  • Detecting/Protecting against security events
  • Internal analytics and reporting
  • Internal research
  • Customer service
  • Operate our business and games
  • Game mechanics or functionality
  • Facilitate players' social interactions
  • Debugging existing intended functionality
  • Product development/improvement
  • Maintaining and enhancing service
  • Auditing consumer interaction & transactions
  • Advertising
  • Direct marketing (phone, email, etc.)
  • Player acquisition
Internet/Network Information, such as website or application or advertisement browsing history.
  • Players
  • Players’ Devices
  • Data Services
  • Service Providers
  • Analytic Services
  • Detecting/Protecting against security events
  • Internal analytics and reporting
  • Internal research
  • Customer service
  • Operate our business and games
  • Game mechanics or functionality
  • Facilitate players' social interactions
  • Debugging existing intended functionality
  • Product development/improvement
  • Maintaining and enhancing service
  • Auditing consumer interaction & transactions
  • Advertising
  • Direct marketing (phone, email, etc.)
  • Detecting/Protecting against security events
Geolocation Data, IP Address, device shared location, and Wi-Fi connection location.
  • Players
  • Players’ Devices
  • Data Services
  • Service Providers
  • Detecting/Protecting against security events
  • Internal analytics and reporting
  • Internal research
  • Customer service
  • Operate our business and games
  • Game mechanics or functionality
  • Facilitate players' social interactions
  • Debugging existing intended functionality
  • Product development/improvement
  • Maintaining and enhancing service
  • Auditing consumer interaction & transactions
  • Advertising
  • Direct marketing (phone, email, etc.)
  • Player acquisition
Inferences such as derivation of information, data, assumptions, or conclusions from any of the above categories of personal information.
  • Players
  • Players’ Devices
  • Data Services
  • Service Providers
  • Social Network Services
  • Analytic Services
  • Detecting/Protecting against security events
  • Internal analytics and reporting
  • Internal research
  • Customer service
  • Operate our business and games
  • Game mechanics or functionality
  • Facilitate players' social interactions
  • Debugging existing intended functionality
  • Product development/improvement
  • Maintaining and enhancing service
  • Auditing consumer interaction & transactions
  • Advertising
  • Direct marketing (phone, email, etc.)
  • Player acquisition

Disclosure of Personal Information

In the last 12 months, we have disclosed the following categories of personal information.

Category of Personal Information Disclosure for a Business Purpose Sold*
Identifiers Yes No
California Customer Records <(Cal. Civ. Code § 1798.80(e)) Yes No
Protected Classification Characteristics Yes No
Commercial Information Yes No
Internet/Network Information Yes No
Geolocation Data Yes No
Inferences Yes No

*Sumi Labs does not "sell" personal information about our players as most people would typically understand that term. However, we do allow certain third-party advertising partners to collect information about consumers through our games and our website for purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for ad fraud detection and reporting. To the extent this practice is interpreted to constitute a "sale" under the CCPA, please see our Online Advertising section below for more information.


To Whom We Disclose Personal Information

As described in the How We Share Information section of the Privacy Policy, we share personal information within Sumi Labs and with a variety of recipients for business purposes.

In addition to the categories of recipients identified in the How We Share Information section of the Privacy Policy, we disclose personal information to, or allow access to personal information by, the following categories of recipients:

  • Customer Service Vendors
  • Quality Assurance Vendors
  • Cloud Storage Providers
  • Payment and Auditing Processors
  • Security Safety Vendors and Service Providers
  • Social Media Services
  • Advertising and Marketing Partners

Online Advertising

We allow certain third-party advertising partners to collect the categories of personal information identified above for online advertising purposes. These ad networks, social media companies and other third-party businesses in the ad ecosystem collect personal information directly from a browser or device through cookies or similar tracking technologies when a consumer visits or interacts with our websites, uses our apps or otherwise engages with us online. These third parties use your personal information to:

  • serve relevant ads on our site, on other websites or mobile apps, or on other devices a consumer may use;
  • to personalize content; and
  • to perform other advertising-related services such as reporting, attribution, analytics and market research.

These third parties may use this personal information for their own commercial purposes in accordance with their own privacy policies, which may include providing this information to additional third parties, including other advertising networks.

Please see our About Cookies notice for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.


Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know

You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information we have collected about you;
  • The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold about you, and the categories of third parties to whom this information was sold; and
  • The business or commercial purposes for collecting or selling personal information about you.
The Right to Request Deletion You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt-Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of the rights described above.

However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
"Shine the Light" California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s "Shine the Light" law (Civ. Code § 1798.83).

How to Exercise Your California Privacy Rights

To Exercise Your Right to Know or Right to Deletion

To exercise your right to know and right to deletion, please submit a request by emailing support@sumilabs.com with the subject line "California Rights Request."

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and the right to deletion of personal information, certain requests may require us to obtain additional personal information from you. 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.

To Exercise Your Right to Opt-Out of Personal Information "Sales"

Unless you have exercised your right to opt-out of personal information "sales", we may "sell" personal information to third parties, as that term is defined under California law. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include re"sell"ing this information to additional third parties.

To exercise your right to opt-out, please submit a request by sending a request to support@sumilabs.com

Do Not Sell My Info

You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems and authenticate you as authorized to receive the information.

Once you make an opt out request, you may change your mind and opt back in to personal information sales at any time by contacting us at support@sumilabs.com.

"Shine the Light"

To ask us for a notice describing what categories of personal information Sumi Labs shares with third parties or affiliates for those third parties or affiliates’ direct marketing purposes and identifying the name and address of the third parties that received such personal information, please submit a written request to the address provided in the Contact Information section of our Privacy Policy above and specify that you want a copy of your "Shine the Light" California Privacy Rights Notice.

Minors Under Age 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Authorized Agent

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.

Authorized Agent

We may offer incentives in exchange for the retention or sale of personal information:

In-Game Rewards & Currency: We offer nominal in-game currency and rewards to users when they choose to watch in-game video advertisements or connect their Facebook account. When a user chooses to receive the in-game currency and rewards, Sumi Labs and its advertising partners use the information collected to serve the user with more relevant ads. Video and other relevant advertisements help support the game’s operation. A user can choose not to receive the in-game rewards and currency by electing not to watch in-game advertisements or by disconnecting their Facebook account through Facebook’s user settings.

Updates

We may update this CA Notice from time to time. When we make changes to this CA Notice, we will change the "Last Updated" date at the beginning of this CA Notice. If we make material changes to this CA Notice, we will notify you by email to your registered email address, by prominent posting on our online services, or through other relevant communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and privacy practices, please send an e-mail to support@sumilabs.com. For all other matters, please contact Sumi Labs through either at support@sumilabs.com or within the game.