Legal and Privacy

1. Controller – Who are we?

We are Fortis Games. We determine the purposes and means of the processing operations described in this Privacy Policy, and we are therefore the ‘controller’ under applicable data protection laws, or the equivalent term in your region. Where this Privacy Policy refers to Fortis Games (“we”, “us” and “our”), this refers to the specific entity in the Fortis group, consisting of Fortis, LLC and its affiliated entities and offices, with which you have a contractual relationship or have otherwise interacted. We have local representatives in several regions. For privacy-related questions, you can contact us via e-mail at privacy@fortisgames.com or as specified in the Contact Us section below. The Contact Us section also provides more information regarding our local representatives.

2. Personal Data – How do we collect, use and disclose your personal data?

We may collect, use and disclose (and may have collected, used and disclosed during the 12-month period preceding the Last Updated date of this Privacy Policy) personal data as described below. For residents of the United States only, we may sell (and may have sold during the same period) personal data as described below. Below this chart we have included additional details about the processing purposes and categories of third parties to whom personal data is disclosed.

Personal Data: Contact data, such as name, email address and telephone number

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Affiliated entities
• Third-party service providers
• Advertising and social media partners
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Advertising and social media partners

Personal Data: Demographic data, such as your age, gender and location (city, country, timezone)

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Affiliated entities
• Third-party service providers
• Advertising and social media partners
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Advertising and social media partners

Personal Data: Profile data, such as your login credentials (username and password), unique user ID, public screen name, profile picture and avatar; and other account details

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Tailored Offers
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Other players and users
• Affiliated entities
• Third-party service providers
• Advertising and social media partners
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Advertising and social media partners

Personal Data: Gameplay data, such as information about the Services you use (including the relevant game name, version and language) and your use of the Services (such as the duration and time of your use of the Services, in-game actions and location, player level, game progress and results, collaboration and participation in teams, and participation in matches, battles, missions and other game events), as well as personal data required for specific settings or features of the Services (such as your wishlist, multiplayer and communication features, including in-game chat, voice chat, video chat and friend list)

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Tailored Offers
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Other players and users
• Affiliated entities
• Third-party service providers
• Advertising and social media partners
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Advertising and social media partners

Personal Data: Transactional data, such as products or services purchased, obtained or considered, other purchasing or consuming histories or tendencies, payment information, information about offers purchased and viewed, refunds, gift transactions and related currency

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Tailored Offers
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Other players and users
• Affiliated entities
• Third-party service providers
• Advertising and social media partners
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Advertising and social media partners

Personal Data: Technical and traffic data, such as information about your hardware (such as device brand, model, device ID, language, available memory, power status or other device-related specifications), your operating system and settings, browser and network (such as network type, internet service provider, plugins, IP address), and technical information about your use of the Services (such as timestamps of your logins and in-Service activities, products and services viewed in the Services, URLs visited, referring and exiting webpages, number of clicks, crash reports and traffic data)

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Tailored Offers
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Other players and users
• Affiliated entities
• Third-party service providers
• Advertising and social media partners
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Advertising and social media partners

Personal Data: Geolocation data related to your device if you provide us with permission to collect this data, which may be considered "sensitive" under applicable privacy laws. We do not process sensitive personal data to infer characteristics about individuals

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Affiliated entities
• Third-party service providers
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Not sold or shared for targeted advertising

Personal Data: Marketing data, such as your opt-in/opt-out choices for receiving promotional messages, push notifications, in-game offers, personalized ads, advertising IDs, and information about your interactions with advertisements, such as impressions, clicks and views

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Tailored Offers
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Affiliated entities
• Third-party service providers
• Advertising and social media partners
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Advertising and social media partners

Personal Data: Social media data, such as information about your (linked) social media profile (such as Discord, Facebook, Twitch), your posts, comments, 'likes' and other interactions on social media platforms in relation to the Services

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Affiliated entities
• Third-party service providers
• Advertising and social media partners
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Not sold or shared for targeted advertising

Personal Data: Security data, such as information required for security of the Services, such as multi-factor authentication, player reports, fraud detection mechanisms, anti-cheat monitoring, ban enforcement and security logs

Processing Purposes:

• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities

Disclosures:

• Affiliated entities
• Third-party service providers
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Not sold or shared for targeted advertising

Personal Data: Legal, compliance and corporate data, such as personal data required for compliance with legal obligations, in connection with disputes and legal rights, or corporate developments

Processing Purposes:

• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Affiliated entities
• Third-party service providers
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Not sold or shared for targeted advertising

Personal Data: Miscellaneous data, such as other personal data you choose to provide to us, such as through email, a chat or messaging feature made available in the Services or online forms, surveys and other interactions with us.

Processing Purposes:

• Services
• Product and Services Development, Improvement and Testing
• Marketing
• Tailored offers
• Analytics
• Compliance with Legal Obligations
• Security Maintenance and Improvement of Our Systems and Services
• Prevention, Detection and Investigation of Unlawful and Unwanted Activities
• Corporate Developments
• Disputes and Legal Rights
• Anonymization & Aggregation

Disclosures:

• Affiliated entities
• Third-party service providers
• Other companies and authorities

Sold/Shared for Targeted Advertising (United States only):

• Not sold or shared for targeted advertising

We may collect the personal data described above directly from you or your device, such as when you interact with the app, or through email, chat, or messaging features made available in the Services, or online forms, surveys and your other interactions with us.

We may also collect personal data from public sources, such as data analytics providers, advertising partners, app stores, and game providers and publishers. The personal data we may receive from such third parties also include Marketing data. Additionally, we may receive personal data from parties with whom we share personal data, as listed below in the section Data Sharing – Who may receive your personal data?

2a. Use of Personal Data – For what purposes do we process personal data?

We may process personal data for a variety of purposes. The chart below provides details regarding each processing purpose and the corresponding legal basis for the relevant processing. We may use artificial intelligence, machine learning, and similar technologies when we process personal data for the purposes listed below

Purpose: Services

Description:

• Enable you to create, verify and manage your account
• Determine the relevant settings and features of the Services based on age and location
• Provide you with the Services, as well as customer service (including through automated live chatbot features on our Services), technical support and assistance
• Facilitate your use of specific features the Services, such as location based services or voice chat
• Keeping our Services safe and fair, including to monitor and review communications for content moderation purposes
• Communicate with you about the Services, including via e-mail alerts, and to communicate with you about your requests or comments regarding the Services
• Personalize your gameplay experience through the Services

Legal Basis:

• Performance of our contractual relationship with you
• Legitimate interest
• Your consent

Purpose: Product and Services Development, Improvement and Testing

Description:

• Develop new products and Services, including developing, training and fine-tuning models, algorithms and artificial intelligence technologies, and to grant early access to individuals to such products and Services
• Enhance, troubleshoot and improve our Services
• Manage alpha, beta or early access testing of our Services

Legal Basis:

• Our legitimate business interests to develop and improve our Services
• Performance of our contractual relationship with you

Purpose: Marketing

Description:

• Promote our Services and related products and Services through direct marketing (including based on individuals' preferences)
• Enable your participation in contests and rewards programs
• Organize events relating to our Services

Legal Basis:

• Your consent
• Our legitimate business interests to pursue marketing activities where allowed

Purpose: Tailored Offers

Description:

• Offer special rewards depending on your progress
• Provide rewards and bespoke in-game offers based on your previous activity, Gameplay data and Transactional data

Legal Basis:

• Our legitimate business interests to provide you with offers that are relevant and aligned with your interests
• Your consent

Purpose: Analytics

Description:

• Analyze our Services and our customer base
• Understand how our Services are used
• Determine the effectiveness of our advertising and marketing activities
• Conduct market research and customer surveys

Legal Basis:

• Our legitimate business interests to perform analytics
• Your consent

Purpose: Compliance with Legal Obligations

Description:

• Comply with legal obligations that apply to us, such as complying with lawful orders from governmental authorities or courts, subpoenas, obligations under tax, financial reporting, employment, consumer protection, and data protection laws.

Legal Basis:

• Legal obligations

Purpose: Security Maintenance and Improvement of Our Systems and Services

Description:

• Maintain and enhance the availability, security and performance of our IT infrastructure and Services
• Detect, prevent, and investigate (suspicions of) data breaches or attempts to unlawfully access our IT infrastructure and Services
• Protect the integrity and security of in-game communications and interactions, including monitoring for spam, fraud, abuse, or other behaviors that may compromise account or platform security
• Implement and operate cybersecurity and information security tools and systems to detect, prevent, and investigate security incidents or attempts to access our systems without authorization

Legal Basis:

• Legal obligations
• Performance of our contractual relationship with you
• Our legitimate business interests to ensure that our Services are secure

Purpose: Prevention, Detection and Investigation of Unlawful and Unwanted Activities

Description:

• Detect, prevent, and investigate (suspicions of) (i) criminal offences, physical or other harm, and other unlawful activities, including cheating, hacking, account stealing, misuse and abuse, (ii) breaches of our Terms of Service and Community Guidelines (with the use of automated content moderation tools), including violations identified through in-game chat and other player interaction; (iii) identify code of conduct violations, harassment, toxic behavior, discrimination, and similar unwanted activities and (iv) to file reports of such events with relevant law enforcement bodies (including any related cooperation)

Legal Basis:

• Legal obligations
• Performance of our contractual relationship with you
• Protect the vital interests of individuals who use our Services
• Our legitimate business interests to prevent, detect and investigate unlawful activities

Purpose: Corporate Developments

Description:

• Sale or transfer of all or part of our business or assets, or any other actual or potential corporate events, such as mergers, acquisitions, joint ventures, reorganizations, financing transactions, a divestiture, dissolution, or liquidation.

Legal Basis:

• Legal obligations
• Our legitimate business interests to facilitate business continuity, enabling due diligence, and supporting the evaluation, negotiation, and completion of corporate transactions in a secure and compliant manner

Purpose: Disputes and Legal Rights

Description:

• Protect and enforce our legal rights and contracts (including our Terms of Service and Community Guidelines) in connection with actual or threatening disputes, legal proceedings, claims, investigations and similar events.

Legal Basis:

• Performance of our contractual relationship with you
• Legal obligations
• Our legitimate business interests to protect and enforce our legal rights

Purpose: Anonymization & Aggregation

Description:

• Anonymize and/or aggregate personal data for our business purposes including, without limitation, improving our products and Services based on usage patterns, optimizing marketing and advertising effectiveness, conducting comprehensive market research and demographic analysis, informing strategic business decisions and resource allocation, strengthening fraud detection and risk management systems, benchmarking, supporting research, development and safety initiatives for new offerings, including those based on chat or behavioral data, and identifying emerging consumer trends. We will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Legal Basis:

• Our legitimate business interests to develop and improve our Services

We also may use personal data for additional purposes that we specify at the time of collection.

You may be required to provide certain personal data to us, for instance by contract or by law. Fields in online forms with an asterisk (*) indicate information that is mandatory to submit the form. If you fail to provide mandatory information, this may affect our ability to provide you with our Services, our contractual relationship with you, or the Services may not operate as intended.

2b. Data Sharing – Who may receive your personal data?

Your personal data may be shared with or accessible to others outside of Fortis Games, including the following:

• other players and users – when you engage with social features within our Services, your personal data may be visible to other players and users, such as in multiplayer environments, leaderboards, or user-generated content interactions with other players and users;
• affiliated entities – personal data may be accessible to other entities within our group of companies in connection with shared systems, central administration and operational efficiency;
• third-party service providers – we work with third-party service providers who assist in developing and operating our Services (such as platform services, game developers, game publishers, game console providers, customer support service providers), and managing business operations (such as hosting, analytics, payment processing, customer support);
• advertising and social media partners – our Services include features from our advertising and social media partners, such as social media interaction tools, functionalities through application programming interfaces (APIs) or software development kits (SDKs) and in-game advertising. These partners may access personal data (such as device and activity data, IP address, mobile identifiers, pages visited, location and usage patterns) through these technical integrations and process it further under their own privacy policies (see Appendix A – Third Party Partners); and/or
• other companies and authorities – we also may disclose personal data about you to other companies and authorities (1) if we are required or permitted to do so by applicable law, regulation, or legal process (such as a court order or subpoena); (2) to law enforcement authorities and other government officials to comply with a legitimate legal request; (3) when we believe disclosure is necessary to prevent physical harm or financial loss to the Company or players or users as required or permitted by law; (4) to establish, exercise, or defend our legal rights; and (5) in connection with an investigation of suspected or actual fraud, illegal activity, security, or technical issues.

We do not sell personal data in exchange for monetary consideration. We may share personal data by allowing certain third parties to collect personal data via automated technologies on our Services for cross-context behavioral advertising or targeted advertising purposes. This kind of sharing may be considered a “sale” or sharing for cross-context behavioral advertising/targeted advertising purposes under certain privacy laws (e.g. United States) when the personal data is exchanged for non-monetary consideration. For a list of the specific third parties to whom we sell personal data please see our Appendix A – Third Party Partners. For residents of California only: we do not have actual knowledge that we sell or share or share for targeted advertising purposes personal data of minors under 16 years of age.

3. Data Retention – How long do we keep personal data?

We retain personal data for as long as necessary for the purposes for which we collected it. It may also be necessary to retain personal data longer for the purposes described in this Privacy Policy, such as crime prevention, compliance with legal (retention) obligations, disputes and enforcement of our legal rights.

4. Privacy Rights – Which rights do you have in connection with your personal data?

Depending on your region and applicable data protection laws, you may have certain rights regarding the processing of your personal data. These rights commonly include:

• right to access – the right to request access to your personal data, obtain a copy of such personal data and receive specific information about the processing of your personal data;
• right to rectification – the right to have inaccurate or incomplete personal data corrected or supplemented;
• right to erasure (‘right to be forgotten’) – the right to request deletion of your personal data.

In certain regions, you also have the right to object to processing, restrict processing, receive your personal data in a structured, commonly used, and machine-readable format (‘data portability’), and not to be subject to automated decision-making. You can submit a request to exercise your rights through the support channels available in our Services, or by contacting us as specified in the Contact Us section below. When you submit a request to exercise your rights, we will assess whether the right is available to you in your region, and whether it is subject to any conditions, restrictions or exceptions under applicable data protection laws. We also may take steps to further verify your identity.

In addition to the rights listed above, in most regions you have the right to lodge a complaint regarding the processing of your personal data with the local supervisory authority. You can also file a complaint with us by contacting us as specified in the Contact Us section below, in which case we will respond as appropriate.

Our U.S. State Privacy Supplement (Appendix B) provides additional information for residents of certain U.S. states. To the extent information regarding a specific region contradicts information provided in the general part of this Privacy Policy, the information regarding the specific region prevails.

5. International Transfers – How and where do we transfer personal data?

We may transfer the personal information we collect about you to countries outside of the country in which the information originally was collected, including the jurisdictions in which our service providers operate. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will implement appropriate safeguards to help ensure that we protect that information as described in this Privacy Policy and in accordance with applicable law.

Where a competent authority in your region (such as the European Commission for countries within the European Economic Area) has recognized a country as providing an adequate level of data protection, we rely on such adequacy decision. If not, we implement appropriate safeguards when making international transfers (for example, we use data transfer agreements that incorporate specific contractual clauses that are recognized by the competent authority in your region as valid and effective in providing your personal data with an equivalent level of protection under the laws of your country). Alternatively, we may rely on your consent for cross-border transfers of personal data, including if required by the law in your region. Unless such law requires explicit consent, you acknowledge and consent to our conduct of such cross-border transfers of personal data by agreeing to this Privacy Policy and through your use of the Services. If you are a resident of the European Economic Area or the United Kingdom and would like to obtain a copy of the safeguards we have put in place, please contact us as specified in the Contact Us section below.

6. Data Security – How do we protect personal data?

We implement and maintain appropriate organizational, technical and physical measures designed to safeguard the personal data we obtain against accidental, unlawful, or unauthorized access, destruction, loss, alteration, disclosure or use.

7. Children’s Data – How do we protect children’s privacy?

Our Services are designed for a general audience and are generally not directed to children (under the age of 13, or the applicable minimum age in your region as required by law). In general, we do not knowingly solicit or collect personal data from children without legally required safeguards. To the extent our Services may be appealing to children, we implement additional safeguards to provide children with a restricted, age-appropriate version of the Services with limited features and/or we may obtain parental consent where necessary. We strive to provide a safe and secure experience for all users. If you believe that a child may have provided us with personal data without legally required parental consent, please contact us as specified in the Contact Us section below. A parent or legal guardian may also exercise applicable privacy rights on behalf of their child. Please see our Children’s Online Privacy Policy (Appendix C) for more details.

8. Sensitive data

We do not intentionally collect sensitive personal data (such as racial or ethnic origin, political opinions, religious or philosophical beliefs, health information, or biometric data), unless we explicitly request you to provide such personal data for a specific purpose and with appropriate consent. Unless we explicitly request you to do so, please do not provide such personal data when using our Services or communicating with us. If you do, we reserve the right to delete such personal data.

9. Cookies and Related Technologies

When you visit, use, or otherwise access our Services, we may obtain certain information by automated means, such as cookies, local storage, web beacons, web server logs, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The cookies and related technologies our Services use can be divided into the following categories:

• strictly necessary cookies, which are necessary for the Services to function and cannot be switched off;
• performance cookies, which allow us to measure and improve the performance of the Services;
• functional cookies, which enable enhanced functionality and personalization of the Services;
• targeting cookies, which may be set by our advertising partners;
• social media cookies, which are set by a range of social media services that we have added to the Services to enable you to share our content with your friends and networks.

Where required by applicable law, we will obtain your consent for the use of cookies and related technologies. You can set your preferences and find more detailed information about the specific cookies and related technologies used by our Services by (i) clicking the Your Privacy Choices link located at the bottom of the page if you are on our website or (ii) clicking the Your Privacy Choices button in the in-game settings if you are playing one of our games.

10. Links to Third-Party Services and Features

For your convenience and information, our Services may provide links to other online services, and may include third-party features such as apps, tools, widgets, and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy policies of these parties, which we strongly suggest you review (see Appendix A – Third Party Partners). To the extent any linked online services or third-party features are not owned or controlled by us, we are not responsible for these third parties' information practices.

11. Contact Us

We encourage you to use the contact forms on our website and in our Helpshift, since these are the most convenient ways to get in touch with us. You can also contact us using the below contact details:

Fortis Games

Attn.: Legal Department
E-mail: privacy@fortisgames.com
Address: 3883 Howard Hughes Parkway, Suite 550, Las Vegas, Nevada, 89169, USA

Below is an overview of our local representatives.

EU and EEA
Attn.: DataRep
Email: fortis@datarep.com
Address: The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland

Switzerland
Attn.: DataRep
Email: fortis@datarep.com
Address: Leutschenbachstrasse 95, ZURICH, 8050, Switzerland

United Kingdom
Attn.: DataRep
Email: fortis@datarep.com
Address: 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

12. Updates to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our privacy practices. If the changes made to our Privacy Policy are material, we will provide additional notice to you where legally required, such as through email. At the top of this Privacy Policy you can see when it was most recently updated. Previous versions are available upon request. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

13. Translations

This Privacy Policy is originally written in English. Any translations of this Privacy Policy that we may provide are for convenience only and are not legally binding. In the event of any discrepancies or inconsistencies between the English version and any translation, the English version shall prevail and govern.

Appendix A – Third Party Partners

This list provides links to the privacy policies of third-party partners on external sites. By clicking these links, you will be redirected to external sites which are not managed by us.

AppLovin

BugSnag

CleverTap

Facebook

Firebase

Google

Helpshift

K-ID

OneTrust

Survey Monkey

Singular

Tiktok

Variance

Appendix B – U.S. State Privacy Supplement:

This U.S. State Privacy Supplement applies to residents of certain U.S. states with currently effective consumer privacy laws and supplements our Privacy Policy. This Supplement uses certain terms that have the meaning given to them under applicable U.S. state privacy laws.

Notice of financial incentives for California Residents: By accepting a marketing offer for virtual currencies, you agree to provide certain personal information for use by Fortis, such as your email address. You can opt into this offer by completing the sign-up form. You have the right to opt out at any time. You can opt out of receiving marketing emails by clicking the “Unsubscribe” link in our emails. We estimate that the value to Fortis of the personal information you provide in connection with this offer is equivalent to the amount of virtual currency provided by the offer.

This Statement does not apply to Fortis Games personnel or job applicants.

1. Privacy Rights

Depending on your state of residence, if you interact with us in an individual or household capacity (and not in a commercial or employment context), you may have certain rights regarding your personal data, as described below.

• Access: You have the right to request (1) confirmation of whether we process your personal data and (2) access to the personal data we maintain about you, including a copy provided in a portable format. Depending on your state of residence, you also may have the right to request information about (1) the categories of personal data we have collected, used, disclosed and sold or shared about you, (2) the categories of sources from which the personal data is collected, (3) the business or commercial purpose for collecting, selling or sharing personal data, and (4) the third parties or categories of third parties to whom we disclose personal data.

• Correction: You have the right to request that we correct the personal data we maintain about you, if that information is inaccurate.

• Deletion: You have the right to request that we delete certain personal data we have collected from you.

• Shine the Light Request: If you are a California resident, you also may have the right to request that we provide you with (a) a list of certain categories of personal data we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

• Opt-Out of Sale or Sharing for Cross-Context Behavioral Advertising/Targeted Advertising: You have the right to opt-out of the sale of your personal data or the sharing of your personal data for cross-context behavioral advertising purposes.

• Profiling: We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.

2. Submitting Privacy Rights

• How to Submit an Access, Correction, Deletion or Shine the Light Request: You can exercise your access, correction, deletion, rights on behalf of yourself or as an authorized agent on behalf of another individual by contacting privacy@fortisgames.com.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal data or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to or deletion of your personal data, we may require you to provide any of the following information: first name, last name, mailing/shipping address, phone, and email address. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal data, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal data is the subject of the request.

• How to Submit an Opt-Out of Sale/Targeted Advertising Request: To opt out of the sale of your personal data or the sharing of your personal data for purposes of cross-context behavioral advertising/targeted advertising, click Your Privacy Choices or use the Global Privacy Control signal (“GPC”). If you would like to opt-out of the sale or sharing of your personal data associated with a different device or browser, please submit an opt-out request or use the Global Privacy Control signal using that device or browser. Please note that if you clear your cookies on a particular browser or device, you may need to resubmit your opt-out request again from that device or browser. Requests sent using the Global Privacy Control will apply to the device and browser from which they are submitted. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org.

3. Appeals

Subject to applicable law, you may appeal our decision with respect to a request you have submitted by emailing us at privacy@fortisgames.com and including “Consumer Privacy Rights Appeal” in the subject line.

4. Additional Information

If you choose to exercise any of your privacy rights under applicable law, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. For questions or concerns about our privacy policies and practices, please contact us as at privacy@fortisgames.com.

Appendix C – Children’s Online Privacy Policy:

Fortis Games is committed to protecting the privacy of children who use our sites and applications. This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”).

Our Services are designed for a general audience and are generally not directed to children, unless otherwise stated on the specific Service's web or store page. In general, we do not knowingly solicit or collect personal data from children without legally required safeguards. To the extent our Services may be appealing to children, we implement additional safeguards to provide children with a restricted, age-appropriate version of the Services with limited features and/or we may obtain parental consent where necessary. We strive to provide a safe and secure experience for all users.

When a user indicates that they are a child under 13, we may collect limited personal data where required by applicable (children’s) privacy laws. When children use our Services, we automatically collect persistent identifiers like IP address, gaming platform account IDs, device identifiers, and similar data collected with online tracking technologies. This information is collected using automated technologies such as cookies, local storage, web beacons, web server logs, and other technologies (which we define under the “Cookies and related technologies” section of this Privacy Policy). This information may be collected by Fortis Games. This data is used for the sole purpose of providing support for the internal operations of our Services, including analytics to improve the Services, to protect the security and integrity of users, to ensure legal and regulatory compliance and to facilitate in-game personalization such as game advancement and a pre-generated avatar. When we share personal data from children externally, it is to help us carry out these limited purposes.

In the event we collect (or allow others to collect) such information from children on our sites and applications for other purposes, we will notify parents and obtain consent prior to such collection.

We retain personal data for as long as necessary for the purposes for which we collected it. It may also be necessary to retain personal data longer for the purposes described in this Children’s Online Privacy Policy.

Please contact us at the mailing address, email, or phone number below with questions about our privacy practices:

Fortis Games
Attn.: Legal Department
E-mail: privacy@fortisgames.com
Address: 3883 Howard Hughes Parkway, Suite 550, Las Vegas, Nevada, 89169, USA
Phone Number: +1 (725) 261-8904