Privacy Policy

Last Revised: April 26th, 2019

Asmodee Digital ("Asmodee Digital", "we" or "us") is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the collection, use and disclosure of personal information of users of our mobile applications (each an "Application") (collectively, the "Site"), and online services ("Services").

This Privacy Policy is attached to the Terms of Use of Asmodee Digital, and serves as an integral part thereof.

The Site and the servers that make the Site available are located in France. Your personal information may be collected and processed in France and may be transferred to other countries in accordance to the terms and conditions of the terms of the Directive 95/46/EC relative to the Protection of the Personal Data.

The Person in charge of collecting data in accordance with this Privacy Policy is Asmodee Digital, a French Société par actions simplifiée whose Headquarters office is located 18 rue Jacqueline Auriol – 78280 Guyancourt, registered with Versailles’ Registry under number 818 058 216,

Collection of Personal Information

1. “Personal Information”, which is the type of information that specifically identifies you personally and/or can be used alone to contact you online or offline, such as your full name, physical address, email address, telephone number, photograph, precise geolocation information (i.e., your specific location), credit card information and, in some cases, usernames; and

2. “Non-Personal Information”, which is information that does not identify you and cannot be used to contact you personally, including information about you such as your date of birth, age, ZIP code, non-precise geolocation information (e.g., your city), and gender, as well as information about your computer and mobile device, such as your unique device ID, or other persistent identifiers, and their hardware/software/firmware. Non-Personal Information also includes “Usage Data,” which is anonymous data tied to your computer and/or device, such as the actions you take within and outside of the Websites/Apps, the browser you use, the identity of other apps included on your device, the date and time of your use of the Websites/Apps, your game progress, play time, score and achievements, and the URLs you visited and/or apps you used before and after using our Websites/Apps.

We collect Personal Information from you in a variety of ways when you use the Site and Services:

• We may collect Personal Information from you, such as your e-mail, zip code, country, birthdate, login name, and password when you create an account to log in to our network ("Account").
• If you use our Services on your mobile device, including through our Application(s), we may collect your phone number and the unique device id number.
• When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
• When you order products or services on our Site or through our Services, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information. This information may be shared with third parties who help process and fulfill your purchases. When you submit credit card numbers, we encrypt that information using industry standard technology.
• We retain information on your behalf, such as files and messages that you store using your Account.
• If you provide us feedback or contact us via e-mail (in particular but not limited to request support), we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
• When you post content on our Site or through our Services, the information contained in your posting will be stored in our servers and other users will be able to see it, along with your login name. This information will be visible to others, including anonymous visitors to the Site.
• Some services provide you with tools and content so you can create / share original content. These user-generated content may be collected by Asmodee Digital and should be considered as Personal Information as long as you will integrate your own personal data or those of another person (eg your name or picture ).
• If you choose to send a message to another user or defined group of users through our message, chat, post or other in-game function, we may collect any Personal Information you may disclose through such means, as well as the necessary Personal Information of the user(s) you are contacting, in order to facilitate the communication (Note: we will never collect any information sent outside of the functionality of our Site, including through emails or text messages).
• When you participate and interact with other users through a chat room or forum, we may collect the content of your voice and text communications, the time and location of your activities and your ID in online and your IP address.
• If you choose to enable push notifications, we may use your Personal Information, or Non-Personal Information such as a device ID, in order to send push notifications to your device.
• When you participate in one of our surveys, we may collect additional profile information.
• We also collect other types of Personal Information that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
• If you participate in a sweepstakes, contest or giveaway on our Site, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last names, and sometimes post office addresses to verify your identity. In some situations we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.
• We may also collect Personal Information at other points in our Site or through our Services that state that Personal Information is being collected; in such situations, we will use such Personal Information for the sole purposes for which you submitted it.
• We may collect precise geolocation information provided that, prior to doing so initially, you will either be informed of this practice or be prompted to allow or block this feature. In the event you proceed with acquiring the Site or choose to allow this feature, you will be able to block it at any time thereafter by taking the appropriate steps in the Settings tab.

We will not collect any Personal Information from you simply by virtue of your utilization of our Site/Services; we only collect it if you choose to submit it to us. We do, however, collect Non-Personal Information such as device IDs, IP addresses and other persistent identifiers, as well as Usage Data, whenever you use our Site. Such Non-Personal Information is not combined with Personal Information unless you choose to submit Personal Information to us.

Information You Provide to Third Party Sites. The Services allow users to login to the Services via Facebook and other third party sites ("Third Party Sites") and to access such Third Party Sites to interact with friends and to share information on such Third Party Sites. If you login to the Services via a Third Party Site or otherwise connect your Third Party Site account to your Account, i) you are allowing the Services to access, store and use pursuant to the terms of this Privacy Policy your information that you shared with the Third Party Sites, and ii) you are agreeing to the Third Party Site's Terms of Use/Terms of Service in your use of the Services. In addition, we may receive information from such Third Party Site to make it easier for you to create an Account on the Site/Services and show our relevant content from your Third Party Site account. Once you register on the Site/Services and connect with a Third Party Site you will be able to automatically post recent activity back to the Third Party Site. Any information that we collect from your Third Party Site account may depend on the Third Party Site's privacy settings, so please consult the Third Party Site's privacy and data practices. You have the option to disable the connection to your Third Party Site account at any time by contacting us at https://asmodee.helpshift.com/a/asmodee-net/.

Our Use of Collected Personal Information

We use the Personal Information we collect for the purposes indicated at the time you provide such information.

In general, Personal Information you submit to us is used either (but not limited) to :

• Provide you with any goods, services and functionality you ordered,
• respond to any requests that you make,
• send you newsletters, promotions or marketing materials,
• contact you in relation to contest registration and prize acceptance,
• facilitate the creation of and secure your Account on our network;
• identify you as a user in our system;
• provide improved administration of our Site and Services;
• improve the quality of experience when you interact with our Site and Services;
• send you administrative e-mail notifications, such as security, or support and maintenance advisories; and respond to your inquiries or other requests.
• aid us in servicing you better.

For instance, if you register in a contest, we will use the registration information to notify contest winners, or if you purchase a product, we will use the billing information you provide to fulfill the order.

We may also e-mail you to provide information on upcoming Asmodee Digital products, updates and promotions, and occasionally, and only with consent at the time you create an Account, we might also e-mail you to provide information on upcoming partners’/third parties’ products, updates and promotions. We will provide you with the opportunity to opt out of receiving such material in the future at any time. Our mailings and e-mails will also include information allowing you to ask not to receive such information in the future.

We may receive testimonials and comments from users who have had positive experiences with our Site/Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user's consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site/Services from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with our Site/Services, you should be aware that any Personal Information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.

In cases of obvious abuse from users of the Site/Services, Asmodee Digital reserves the right to block certain user accounts or certain IP addresses. The IP addresses may be used to identify you in order to enforce the Terms of Use.

Asmodee Digital use your birth date or your age to filter access to its forums and instant messengers based on the official classification. Asmodee Digital can not monitor all chat areas and do not take any commitment in this direction. However, Asmodee Digital reserves the right, in its sole discretion, to remove any content related to your communications without notice. All data collected in this way can be used by Asmodee Digital to enforce its Terms of Use, to respect the law and to protect its rights, its subsidiaries and other users, as well as for the safety of employees and users. This information may be disclosed to any competent administrative or judicial authority.

Personal Information under French Law shall not be disclosed to a third party by Asmodee Digital unless you express prior approval.

Our Use of Collected Non-Personal Information

We may create anonymous data records from Personal Information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data or Non-Personal Information for administrative, analytical, research, optimization, security and other purposes. Specifically, we may use your Non-Personal Information and anonymous date to:

• analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation,
• compile statistics,
• respond to customer service inquiries;
• protect against cheating, crime or fraud, or for other security reasons.

We reserve the right to use anonymous data/Non-Personal Information for any purpose and disclose anonymous data /Non-Personal Information to third parties in our sole discretion.

Information Collected via Technology. To make our Site and Services more useful to you, our servers collect information from you, including your browser type, operating system, Internet Protocol ("IP") address (which is the number assigned to your computer when you surf the Web), domain name, and/or a date/time stamp for your visit. We also gather certain information automatically and store it in log files.

This information includes IP addresses, browser type, Internet service provider ("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data. In addition, we use cookies to collect information (please refer to section “Cookies” below)

We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them).

Cookies help us give you faster access to pages you have already visited, allow you to personalize your pages, and help you to participate in some online activities on our Site. Your IP address and cookies are not connected to any Personal Information.

We may also collect Non-Personal information from your mobile device if you have downloaded our Application(s). Examples of information that may be collected and used include how you use the Application(s) and information about the type of device you use. In addition, in the event our Application(s) crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s).

We use Google Analytics to help analyze how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics only to improve our Site and Services. Google's ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

How We Respond to Do Not Track Signals. We do not currently respond to "do not track" signals or other mechanisms that might enable consumers to opt out of tracking on our Site.

Advertising Messages

Asmodee Digital uses third-party technology for broadcasting advertising messages online which may collect information while broadcasting advertisement messages on the Service and which may temporarily display ads within the Service. The information that is collected and used for the targeted ad may, among other things, consist of: the number of views an ad gets, the mobile device’s unique identifier or other identifiers and device settings, information on your use of the Service, the compatible mobile Terminal, the ad(s) being broadcast, the placement and the duration of the ad(s) in game, and your response to the ad(s) (where applicable). The analysis tools and the technology for broadcasting advertising messages online may use server log files, web beacons, cookies, tracking pixels, and other technology used to collect said information, and may combine the information collected on other Asmodee Digital products and services with information collected on other websites and third party products and mobile services, as well as with demographic studies, advertisement investigations, market studies, and other analytical investigations. This information alone does not constitute personal data. However, if Asmodee Digital combines it with personal data, Asmodee Digital will treat it as personal data in accordance with its Privacy Policy

Cookies

As a data controller, we may collect your personal data via the cookies that we install on the Site. For more information on how your personal data is processed in this context, please read our Information notice on the protection of personal data in the "Collection of Personal Information" and following sections above.

What is a cookie?

A "cookie" is a string of information that is usually small. It is identified by a name and can be transmitted to your browser by a website that you connect to. Your web browser will keep it for a period of time and return it to the webserver each time you reconnect to it.

There are different types of cookies:

• Temporary cookies and permanent cookies: temporary cookies are automatically deleted at the end of your browser session. Permanent cookies stay on your device for longer, for a time that is specific to each cookie, and remain valid until their expiry date (unless they are deleted before by the user).
• Proprietary cookies and third-party cookies: proprietary cookies are cookies that are installed by the Site domain (these cookies are installed by Asmodee Digital). Third-party cookies are cookies that are placed on the user's computer by the server of a domain other than the Site domain (for example, it may be social network cookies or cookies from publishers of audience measurement solutions).

No cookie will be installed on your device without your prior consent, except for some cookies that are used uniquely to enable or facilitate electronic communications, or that are strictly required to provide an online communications service at your express request. You can personalize your consent and preferences using the pop-up tab at the bottom left of this page.

What cookies do we use, for what purposes and how can they be controlled?

The table below lists the different types of cookies used on the Site, along with their purpose(s) and lifetime.

1. Functional cookies

   These cookies are used to make the Site run optimally. They are usually set up to respond to actions you have performed or to a request for services, such as setting your privacy preferences, filling in forms, your chosen language or keeping you logged in.

   Cookie name	Purpose of the cookie	Cookie duration
   dowbearer	Connection session (when user is logged in)	10 days
   dow	User's numerical ID (when user is logged in)	30 days
   dowbearer_timer	Temporary cookie used during log in	1 day
   dow_betatest_terms	Acceptance of Beta Testing terms (only for logged in user who ask to become beta testers)	30 days

2. Analysis cookies

   We use Google Analytics to measure and improve the performance of our Site. Google Analytics help us to find out which pages are the most or least visited and to see how visitors browse on the Site. Google Analytics uses analysis cookies. All information collected by these cookies is aggregated and therefore, is anonymous.

   Cookie name	Purpose of the cookie	Cookie duration
   dow_consentcookie	Google Analytics acceptance or refusal from user	1 year

   Further information on the cookies generated by Google Analytics is available from the Google Privacy Policy

You can opt out of these cookies or delete them at any time by disabling cookies as indicated in the previous section. In this case, we will not be able to determine when you visit the Site.

Cookies Policy update

We may change this Cookies Policy from time to time, for example, to take into account legal changes, technological progress and best business practices. We will inform you if there are any substantial changes.

Contact

For any questions on the cookies used on our Site, you can contact us at https://asmodee.helpshift.com/a/asmodee-net/

The Sharing of Personal Information

Asmodee Digital will never share, sell, rent or otherwise provide/transfer your Personal Information to any outside companies or other party without your explicit consent except as described below.

With your prior consent, Asmodee Digital may provide your information to outside companies that offer products or services that may be of interest.

We may share your Personal Information with third party service providers to:

• provide you with the Services that we offer you through our Site/Services;
• conduct quality assurance testing;
• facilitate creation of accounts;
• provide technical support;
• and/or provide other services to us.

If we do so, we require those other companies to sign confidentiality agreements, to be bound by this Privaly Policy, and these companies will be authorized to use your Personal Information only for the purposes for which they are engaged.

For instance,

• We may share non-precise geolocation information or precise geolocation information (if you choose to allow us to collect it) with advertisers to allow them to display more relevant and geographically appropriate advertisements to you.
• We may share your Usage Data and Non-Personal Information, such as device IDs, advertising IDs or other persistent identifiers and non-precise geolocation information with our advertising partners. Those partners may use your Non-Personal Information to serve you tailored advertisements outside of our Site/Services: please note that this sharing is limited to anonymous, aggregated Non-Personal Information only and we will not share your Personal Information with advertisers without your prior consent.
• When you make purchases on the Site/Services, Asmodee Digital may share with external service providers your name, postal address, email address, country and your payment details, ( number of your card, the name of cardholder, expiry date and security code) in order to allow the proper functioning of services of processing payments by credit card and delivery of products, delivery or prices of products offered as part of promotions. We keep details of your payments, as well as details of purchases you make. Details of transactions is kept either at Asmodee Digital’s office or at the office of our external service provider, if we use an external provider. This store is done for internal purposes as well as for internal auditing, accounting, compliance and legal purposes.You may be asked to provide the name of your telecom operator, the model of your mobile phone and a valid mobile number in order to provide purchase instructions directly through your mobile phone.

We may share some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy.

We may share some or all of your Personal Information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.

In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset.

If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

Some of our Applications and Services may enable you to post content to Third Party Sites. Our Site/Services also offer social sharing features such as “Share” or “Like” on Third Party Sites. If you decide to use such features, it may allow the sharing and collection of Personal Information and Non-Personal Information both to and from such Third Party Sites. You acknowledge and agree that you are solely responsible for your use of the Third Party Site and that it is your responsibility to review the terms of use and privacy policy of the Third Party Site. We will not be responsible or liable for: (i) the availability or accuracy of the Third Party Site; (ii) the content, products or services on or availability of the Third Party Site; or (iii) your use of the Third Party Site.

The Site/Services may allow you to create a public profile that may allow you to disclose and share publicly some of your Personal Information such as photos, posts, friends, and other contents. Unless otherwise provided on the Site /Services, these Personal Information that you provide to us when you register or update your profile are displayed on your public profile and those you post to the Site are also meant for public consumption. We may display this content on the Site, and further distribute it to a wider audience through third party sites and services. Once displayed on publicly viewable web pages, that information can be collected and used by others. We cannot control who reads your posting or what other users may do with the information that you voluntarily post, so it is very important that you do not put Personal Information in your posts. Once you have posted information publicly, while you will still be able to edit and delete it on the Site, you will not be able to edit or delete such information cached, collected, and stored elsewhere by others (e.g., search engines). You can change the privacy setting at any time

If Asmodee Digital believes disclosure of Personal Information is necessary to defend the rights or property of us or our Site and Services or anyone else, we may disclose the relevant Personal Information. We may also disclose personal information if we believe that the disclosure is required by law, or in response to a legal request in particular but not limited if the information relates to actual or threatened harmful conduct, to investigate and/or take action against illegal activity, suspected abuse or unauthorized use of the Site/Services, or to protect the property or safety of others.

We will never share, sell, rent or otherwise provide a minor Personal Information to any outside company for commercial prospection or solicitation purposes without the minor legal representative’s express consent.

Unsubscribing from Announcements - Opt-out Policy

From time to time, we send announcements by e-mail: news about coming games, important changes in our Site or Services, special offers, etc. Like you, we despise "spam," so we are very reasonable in the number of messages we send. We also try to only send messages that are relevant to your Account. For example, we send pre-order offers of Colt Express expansions only to users who registered their copy of Colt Express. You may choose to completely turn off these announcements at any time by going to your profile. If you are not logged in to your account, you may also use the Unsubscribe page and enter the e-mail address that you used for your Account. Please note that if you unsubscribe, you will not receive any e-mails from us at all - even privileged offers. If you change your mind later, you may turn the announcements back on by returning to your profile.

Cancelling your account

To cancel your account, contact us using the Customer Service page. After cancellation, you will not be able to use your Account anymore. Online gaming, services, privileges and other features will no longer be available to you. No refund will be issued for features or services that you have previously paid for.

Your Rights

Pursuant to the terms of the Directive 95/46/EC relative to the Protection of the Personal Data, any person can correct, supplement, update, block or erase data affecting him or her when errors, inaccurate information or data, the collection, use, transfer, keeping of which is forbidden, have been detected.

If you wish to review, update, correct or delete the Personal Information, you may do so in your Account by contacting us at https://asmodee.helpshift.com/a/asmodee-net/ or by editing their profile via the Service. If you completely delete all of your Personal Information, then your Account may become deactivated.

We will use our best efforts to honor your request within 30 days following your receipt.

We may retain an archived copy of your records as required by law. Otherwise Personal information is not retained any longer than necessary for the utilization of the Services/Site or their processing. You can stop all collection of information by the Application(s) by uninstalling the Application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

The automated processing of personal data carried out using the Site/Services is subject to a declaration to the CNIL, the French Data Protection Authority, under the number 1986774.

Third Party Websites

Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Information or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

Security of Your Personal Information

We are committed to protecting the security of your personal information. We and/or our third party partners use a variety of industry-standard security technologies and procedures to attempt to safeguard and protect your personal information collected through the Site/Services from unauthorized access, use, or disclosure. However, please remember that no method of transmission over the Internet or any wireless network, or method of electronic storage, is 100% secure. Therefore, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. We cannot ensure or warrant the security of any information you transmit to us by email and you do so at your own risk.

When we use third parties to assist us in processing your Personal Information or credit card information we take reasonable steps to require that they comply with this Privacy Policy and otherwise protect your Personal Information (including any credit card information).

If there is a breach of security involving your credit card information from our Site/Services, we will inform you immediately and take commercially reasonable steps to rectify such breach.

If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at https://asmodee.helpshift.com/a/asmodee-net/

We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people.

Changes to this Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy here at http://account.asmodee.net/en/legal/privacy/ and we will change the "Last Revised" date above. You should consult this Privacy Policy regularly for any changes.

Privacy Policy Questions

If you have any general questions about our Privacy Policy, please contact us at : https://asmodee.helpshift.com/a/asmodee-net/