Sumi Labs Privacy Policy

Effective Jan 1, 2023

Sumi Labs provides this Privacy Policy to inform you of our policies and procedures regarding our collection, use and disclosure of information. Except as explicitly provided herein, this Privacy Policy applies only to information we receive from users of (i) the website located at sumilabs.com (the “Site”), including any services, features and content accessible or downloadable from the Site, and (ii) any other Sumi Labs application, service or product licensed, downloaded or otherwise accessed by such users through third party websites or sources ((i) and (ii) collectively, the “Service”).

This Privacy Policy applies when your personal information is processed as part of our Services (described below). Please read it because it will tell you how we process your personal information when providing these Services to you. This Privacy Policy is not, however, a contract and does not create any legal rights or obligations.

If you have questions, comments, or concerns regarding our Privacy Policy or practices, please reach out at support@sumilabs.com.

1. Introduction

Sumi Labs develops and publishes games for web, mobile devices and other platforms on which players can use our Services.

For purposes of data protection laws, Sumi Labs LLC. is the “data controller” of your personal information. We will refer to countries in the European Economic Area (EEA), Switzerland and the UK collectively as the “European Countries” in this Privacy Policy.

This Privacy Policy applies whenever your personal information is processed as part of our “Services,” which means our games, products, services, content, sumilabs.com, and/or other domains or websites operated by Sumi Labs. It describes how we process your personal information when providing these Services to you, and your rights and choices concerning your personal information. The Privacy Policy’s sections are listed and hyperlinked in the Table of Contents above for easier navigation.

If you play Sumi Labs’s games or use Sumi Labs’s other Services, your information will be processed in the ways described in this Privacy Policy.

2. Information We Collect and How We Collect It

A. Information About You That You Share With Us Directly

When you use our Services, you may give us personal information directly (for example, details you register with us when setting up your account), and we will store that personal information on our systems and process it for the purposes described in this Privacy Policy.

Depending on the Service, the personal information we collect will be relevant to providing that Service and include some or all of the following:

• your first and last name
• your game username or alias
• your gender
• your age, birthday or age range
• your email address
• your profile photo and/or avatar
• your approximate location
• your contact details including phone number and address
• a password
• details about the games and platforms you use
• links to your profiles on various social networks and social network ID number
• information related to any purchases you make in our Services (see further details below)
• personal information you provide when you ask for help from our customer support team, including the content of that communication with our team
• A note on sensitive personal information. While we typically do not request sensitive or special categories of personal information you may choose to provide this information to us. The meaning of sensitive or special categories of personal information changes from region to region but could include information about your health or, in certain places, types of financial or precise location information. For some Services, we may also ask you to voluntarily provide information about any accessibility requirements you may have to better understand the needs of players and to improve the accessibility of our Services.

B. Information Shared About Others

We may give you the ability to invite people you know to use Sumi Labs Services, including by importing your address book or manually entering their contact information. You are responsible for ensuring your sharing of this personal information with us is compliant with applicable laws. In some countries, this may require you to get permission from the people you invite before you share their information.

We may also get personal information about you from other Sumi Labs users. We process this personal information to help you and your contacts connect through our Services. If you want to remove personal information stored by us, follow any instructions in the Service or see Your Rights below.

C. Information You Generate Using Our Services

When you use our Services, we will collect personal information about the ways in which you use and interact with our Services, such as when and for how long you play our games, which game features and other players you interact with, any purchases you make, what progress or levels you achieve, and other gameplay activities in which you participate. We will also create an Sumi Labs player ID to identify your game account (on sumilabs.com, your Sumi Labs player ID will appear in the URL of your profile page).

If you choose to use communication features in Sumi Labs Services to communicate or share information with other players, then we’ll collect information on what is communicated or shared. This includes:

• your participation in player forums and message boards;
• your public posts or comments on other players’ profiles or gameboards;
• your non-public messages or invitations to other players, made either directly on our websites or through in-game mechanisms;
• your chats with other players (whether by instant message, live chat, or video); and/or
• your posted photos, drawings, or other user-generated content.

D. Payment Information

If you purchase in-game virtual currency or items in a game you play on any Sumi Labs game website, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, email address, and financial information. Where we use payment processors, they do not share your financial information, like credit card numbers, with Sumi Labs, but they may share non-financial information with us related to your purchases, like your name, billing address, and the items purchased.

When you play Sumi Labs’s games or access any of our other Services on connected third-party applications or platforms (like Facebook, Apple, Google, Snapchat, TikTok or Amazon), any purchases you make will be processed by that third-party application or platform and subject to that third-party application or platform’s terms of service and privacy policy. For these purchases, Sumi Labs does not receive your financial information, but may receive non-financial information related to your purchases, like your name, approximate physical location, and the items purchased. The information Sumi Labs receives depends on the Sumi Labs game you’re playing and the third-party application or platform. Sumi Labs’s Terms of Service explain our policies and terms related to charges, billing, third-party credits, and virtual currencies. Please note that purchases of third-party credits or currencies are also subject to those parties’ terms of service and privacy policies.

E. Information We Get About You From Connected Third-Party Platforms

If you play Sumi Labs’s games or access any of our other Services on social networks like Facebook or other connected third-party platforms, Sumi Labs may receive certain information about you from that third-party platform.

Depending on the Sumi Labs game you’re playing, the third-party application, your privacy settings, and, if applicable, your friends’ privacy settings on that third-party application, Sumi Labs may collect and store some or all of the following from the third-party platform:

• your first and last name;
• your profile picture or its URL;
• your user identification number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;
• your friends’ user ID numbers and other public data;
• the email address you provided to that third-party platform;
• your approximate physical location and that of the devices you use to access our Services;
• your gender;
• your birthday, age, and/or age range;
• information about your activities on or through the connected third-party platform;
• other publicly-available information on the third-party platform; and/or
• any other information that you or the provider of the third-party platform share with Sumi Labs.

If you access our Services from a third-party platform or connect our Services to a third-party account, you should also read that third-party platform’s terms of service and privacy policy.

If you are unclear about what information a third-party platform is sharing with us, please go to that platform to find out more about their privacy practices and any options available to you regarding such sharing.

F. Cookies and Other Automated Information Collection

We use cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers) to recognize you and/or your device(s) across different services (both Sumi Labs’s Services and third party services), including for advertising purposes.

A cookie is a small data file that we transfer to your computer’s hard drive. Like many websites, we also use “cookie” technology to collect additional website usage data, to improve the Service and in some cases to enable you to more easily log in to your Account. We may combine information collected through the use of cookies we issue with other information that you provide to us. Sumi Labs may use both session cookies and persistent cookies to better understand how you interact with the Service, to monitor aggregate usage by our users and web traffic routing on the Service, and to improve the Service and our other products and services. A session cookie enables certain features of the Service and is deleted from your computer when you disconnect from or leave the Service. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies.

We, our service providers, and our business partners use these cookies and other similar technologies to process information, including:

• IP address;
• the type of computer or mobile device you are using;
• platform type (like Apple iOS or Android);
• your operating system version;
• your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);
• application performance and de-bugging information;
• your browser type and language;
• referring and exit pages, and URLs;
• the number of clicks on an app feature or web page;
• the amount of time spent on an app feature or web page;
• domain names;
• landing pages;
• pages viewed and the order of those pages; and/or
• what your current progress is in our Services and the date and time of activity.

In some cases, we will connect the information we collect using cookies and similar technologies with your social network ID or Sumi Labs user ID.

If you play Sumi Labs games on a mobile device, in addition to the information we collect using cookies and similar technologies, we may also collect:

• the name you have associated with your device;
• your country;
• your telephone number (if you provide it);
• your specific geolocation (with your permission);
• your mobile contacts (with your permission, as described further in Information Shared about Others above); and/or
• information about the Sumi Labs games and about other third-party applications with embedded Services you have on your device.

If you want to adjust your privacy preferences on your device, please see Your Rights below.

G. Other Sources

We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.

3. Why We Process Your Information and our Legal Grounds

The main reason we process your personal information is to provide you with Services and to improve your gaming experience, but there are other reasons as well. We process your information for the purposes below:

• Provide our Services and create accounts in those Services
• Improve, optimize and personalize our Services and our players’ experiences
• Help you to connect with other people you know and other third-party platforms you use, including communicating with other players
• Communicate with you about the Services you are using or we think you will like, including in-game updates, new Services, pre-registrations and promotional marketing offers
• Customer service and managing player communications, including technical support
• Marketing, research, analytics and delivering contextual and behavioral advertising
• Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners
• Protect the safety and well-being of our players and others
• Where you provide sensitive or special category personal information to us
• Maintain our business operations, including any business transition, like a merger, acquisition by another company, or sale of all or part of our assets
• For security purposes and to prevent fraud or potentially illegal activities, and to enforce our Terms of Service
• Cooperate with public authorities and law enforcement where lawfully permitted or required
• Protect Sumi Labs’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties

Our legal grounds for collecting and using the information described above depends on what the information is, the context in which we collect it and applicable privacy laws. Those grounds are as follows:

• Establish and perform our contract with you (i.e., our Terms of Service )
• For our or our partners’ legitimate interests
• Consent (where applicable)
• Compliance with a legal obligation
• Protect your vital interests or those of another person (for example, another player)
• While we typically do not collect sensitive or special category personal information, where we do this it will be on the ground of consent or other applicable lawful basis

If you have questions, need further information about the legal grounds for processing your personal information, or want to withdraw your consent please reach out to us at support@sumilabs.com.

4. How We Share Information

We may share your personal information from our Services with others in the ways described below.

A. People you know and Other Sumi Labs Players

Sumi Labs’s games and Services support and often encourage you to interact with other players. In most Sumi Labs games, if you play through a social network or connect to a social network (for example, Facebook), your social network friends who also play a Sumi Labs game will see your name, photo, player profile (which may include the information described above in Information About You That You Share With Us Directly), and descriptions of your in-game activity (including any Sumi Labs games you have played).

In addition, in many Sumi Labs games, other players, regardless of whether they are your social network friends, will be able to see your player profile (as described above); view descriptions of your in-game activity; communicate with you within our Services; and send you game requests or friend requests through our Services or the related social network.

B. Third-Party Advertising Including Behavioral Advertising and Analytics

We’ll share some of your information with advertisers to help make the advertisements you see more relevant to your interests when you use our Services. We do not directly share personal information that identifies you with third-party advertisers for their advertising purposes unless you give us your consent, where legally required.

Advertisements that are tailored for your interests may include banner ads on game boards or in Services, such as full-screen ads between moves or games or ads made available through an “offer wall” (in which advertisers offer virtual currency or other in-game items to players in exchange for watching an advertisement, signing up for an account, completing a survey or performing some other activity). Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Sumi Labs.

To enable advertisers, advertising intermediaries, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:

• performance data (like the number of clicks on an advertisement);
• certain device information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
• a unique identifier, such as your social network ID or Sumi Labs player ID; and/or
• other contextual data about your game play (like your level and session length).

In addition to serving you with relevant ads, the information collected may be used to:

• measure how effective advertising campaigns are;
• offer you targeted advertising in third party services for products and services that are more likely to appeal to you;
• undertake web analytics to analyze traffic and other player activity; and/or
• improve our Services.

Advertisers or advertising intermediaries may collect this information through the use of cookies and other similar tracking technologies.

Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Sumi Labs or the social network through which you are playing Sumi Labs’s games.

If you do not want to receive tailored in-application advertisements, please see Your Rights below.

Please note that the practices of third-party companies delivering advertisements on our Services are subject to those companies’ own privacy policies and privacy practices. If you have any questions about how these third-party services use your information, you should review their policies and contact them directly.

C. Safety, Security, and Compliance with Law

Your information, and the contents of all of your online communications in our Services and between you and Sumi Labs may be accessed and monitored as needed to provide our Service and may be disclosed:

• to satisfy any applicable legal obligations;
• when we have a good faith belief that we have to disclose personal information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
• when we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
• to protect the rights or property of Sumi Labs or applicable third parties, including to enforce our Terms of Service.

D. Third-Party Service Providers

We will share your information with:

• third-parties who perform services on our behalf, like payment processing, analytics, analysis, hosting services, customer service, marketing and advertising, including, for example, Firebase, Unity, Amazon Web Services and AppsFlyer.
• our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (including, for example, Apple, Google and Facebook)

E. Sale or Merger

Where we consider a business transition, like a merger, acquisition by another company, or sale of all or part of our assets (like selling a game), we may disclose or transfer your information, including personal information, to the purchaser.

5. Your Rights

Your privacy rights are explained below. These rights apply to information about you, and their scope and applicability can vary across different regions. For example, they could extend to your household or a legal entity or could be exercised by a legal representative on your behalf. We will comply with applicable privacy laws, including any required response times.

Subject to certain exemptions, you have the right to:

• Request a copy of your personal information (known as ‘accessing your data’).
• Delete your information. When you ask us to delete your personal information please remember that there may be lawful limitations on this right. For example, we will keep certain payment records or customer service records where we need to, including for legal or accounting purposes. We’ll also keep information in order to exercise, protect, defend, or establish our rights or the rights of third parties.
• Correct or update your personal information where it is inaccurate. To review and update personal information associated with your Sumi Labs player profile in certain games, visit the “settings” page in that game.
• Opt-out of marketing communications we send you by following the instructions in “Opting Out of Promotional Communications from Sumi Labs” below.
• Where applicable, withdraw your consent at any time directly in the Service or by contact us at support@sumilabs.com. Withdrawing your consent will not affect the processing already undertaken before your withdrawal. Also, it will not affect processing of your personal information under other lawful grounds.
• Object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• Ask that you are not subject to automated decision-making that has a legal effect or any other significant effect on you.
• Complain to a data protection authority. A list of privacy authorities is available here. In certain regions, you also have the right to request compensation if you suffer damage due to unlawful processing of your Personal Data.

For California residents, please also review our California Notice for additional rights. For Nevada residents, please see section 6 below.

You and/or your legal representative can exercise these rights by contacting us at support@sumilabs.com.

Managing Personal Information We Receive From Third-Party Applications / Platforms And From Your Mobile Device

You can manage the information we receive from third-party applications or platforms and from your mobile device as follows:

• To manage the personal information we receive about you from a third-party application or platform where you play our games, like Facebook, Apple, Google, or Amazon, you can update your privacy settings through the third-party application or platform’s “settings” menu.
• For your mobile device, visit the “settings” page or web browser to review the access permissions of each of our Services.

Once we receive your information from a third-party application or platform or from your mobile device, that information is processed by us in accordance with this Privacy Policy.

Opting Out of Promotional Communications from Sumi Labs

To stop receiving promotional emails from Sumi Labs, click on the “unsubscribe” link at the bottom of any promotional email from Sumi Labs. Your unsubscribe request or email preferences change will be processed promptly, and in no event longer than ten business days. During that processing period, you may receive promotional emails that were already scheduled.

If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device’s “settings” menu. Many of our games also offer the ability to turn off push notifications in the in-game “settings” menu.

You can opt out of receiving SMS text messages by texting back STOP to the number we send the text from or by contacting us at support@sumilabs.com, or use the support function in the game.

When we receive an opt-out message from you for SMS text messages, we may send a text message confirming receipt.

Where you opt out of receiving promotional communications from us, you may occasionally hear from us if we need to provide you with non-marketing information about our Services or if we need to request information from you related to the performance of our Services to you.

Opting Out of Third-Party Behavioral Advertising

If you are interested in more information about behavioral advertising and your choices to prevent behavioral web and mobile web advertising from third parties, you may visit the following websites:

• Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising; and
• Your Online Choices website for European-based advertising.

These third-party opt-outs are browser and device-specific and will not apply to your use of Sumi Labs’s Services through other browsers or devices.

If you do not want to receive personalized in-application advertisements from third parties on your mobile device, you may exercise that choice by visiting your mobile device’s “settings” menu and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”). Certain apps, such as the Digital Advertising Alliance’s “AppChoices” app can help you exercise your behavioral advertising choices and are available from some platform providers (such as Apple or Google).

All of the opt-out tools described in this section are provided by third parties, not by Sumi Labs. Sumi Labs does not control or operate these tools or the choices that advertisers and others provide through these tools.

You will still see third-party advertisements in Sumi Labs’s Services after using these opt-out tools, but the advertising will not be tailored to your interests.

6. U.S. Privacy Laws

If you are a California resident, you may be able to exercise additional rights granted by California law in relation to your personal information that we process (subject to certain limitations). For more information, please review our California Notice.

If you are a Nevada resident you may be able to exercise additional rights to opt out of future sales of certain covered information that a website operator has collected or will collect about you. If you are a Nevada resident, you may exercise this right by contacting us at support@sumilabs.com, or through the support function in the game. Please include sufficient information for us to identify you, such as information about previous games you’ve played, or, if applicable, your account information including Sumi Labs ID. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

7. Our Policies Concerning Children

Our Services are not marketed to, or intended for, children. For these purposes, we use the term “children” to refer to someone who is: (a) under 13 years old or, if older, (b) between 13 and 18 years old but under the age at which they can give valid consent to processing of their personal information under applicable data privacy laws. Sumi Labs strives to follow the different minimum age guidelines set by the laws of individual regions when determining the age that children can access certain features of our Services.

Children are not permitted to use these Services, and we do not knowingly collect any personal information from children. Though our Services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as children in our age-gate on such Services, if we allow children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA or other privacy laws (where applicable), or obtain legally valid parental consent.

If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under COPPA or another applicable privacy law, we will take measures to promptly remove that information from our records.

8. International Operations and Transfers

As part of our international operations, we may transfer personal information to our Group Companies, business partners and service providers located internationally for our legitimate business purpose, including for the purposes listed in the Why We Process Your Information and Our Legal Grounds section above. We store personal information about you on servers located in the United States or where our Group Companies, business partners and service providers have their operations.

Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is processed may be different from the privacy laws applicable to the place where you are resident. When we transfer your personal information internationally we treat your personal information securely, lawfully, and in accordance with privacy obligations. For example, in European Countries, this may include transferring personal information to countries deemed safe by the European Commission, implementing the European Commission’s Standard Contractual Clauses or using another approved mechanism for transfers of personal information between our Group Companies, business partners and service providers (where applicable).

9. How Long We Keep Your Information

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary to provide you with the Services or for our legal requirements.

We will retain personal information that is connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

10. Security of Your Information

We implement reasonable and appropriate security measures to help protect the security of your information both online and offline and to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information.

If you have an account registered directly with Sumi Labs, your profile information is protected by the password you use to access your Sumi Labs account. It is important that you protect and maintain your Sumi Labs account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your Sumi Labs account, the Services allow you to request that instructions be sent to you that explain how to reset your password. Where you access our Services through another account (for example, a social network) please keep that account information secure as well. We urge you to log out of your Sumi Labs account and any social network account you have used to access our Services when you are finished using them.

While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk.

11. Changes to Our Privacy Policy

We may update our Privacy Policy from time to time. When we do, we will revise the “last updated” date at the top of the policy. If we make changes that we deem material, we will use reasonable efforts to notify (such as by placing a notice in game or on sumilabs.com, or by sending you a notice to the email address you have registered with us, if any). We encourage you to periodically check sumilabs.com and this Privacy Policy for updates.

12. Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or privacy practices, please send an email to support@sumilabs.com, or contact us in game.