Last updated: 26 November 2023

Intro

Hello! Welcome to Szone Privacy Policy. This policy describes how Szone collects, uses, processes, and shares information about you.

This Privacy Policy applies to your download, access, and/or use of Szone Games, whether on your computer, on a mobile device, on our website www.szonestudio.com (the “Website”), or any other website, device, or platform (each a “Game” and together the “Games”). This Privacy Policy also applies to any other Services that we may provide about our Games or our Website, such as customer support, social media, community channels, and other websites that we may operate from time to time (we refer to all our Games and other services collectively as our “Services”).

When you download, access, and/or play our Games, or interact with our Websites or other Services you acknowledge the collection and use of your information under this Privacy Policy, including Szone’s and our advertising partners’ use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. Those sections also explain how you can opt in or out of the use of your personal information for targeted advertising purposes. If you have any concerns about providing information to us, or it being used as described in this Privacy Policy, you should not use our Games or other Services.

Playing our Games

When you download, access, and/or play our Games or use our other Services, we collect information about you. Most of this information comes directly from you or your device, such as device information, country, region, and game-play information. We use this information to provide our Games and Services to you, including for optimization, preventing fraud, customizing in-game offers, and verifying purchases. We will also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising purposes.

Most of the information that we collect about you comes directly from you when you play our Games or interact with our Websites, advertising or other Services. Broadly, the information we collect about you relates to the type of device you are using, and how you play our Games (such as levels attempted and purchases made) and will include information that you submit when creating an account with us or which you allow us to access when you connect to your Social Network accounts through our Games or other Services. We will also collect information from advertising platforms partners and other third parties such as information about your purchases and interests.

In more detail, depending on which of our Services you interact with, we will collect and process the following types of information:

• information about how you use and interact with our Games, advertising, and other Services (for example, information about how and when you play our Games or visit our Websites, and what device you use to access our Services. 
• information that you provide us with when you fill in forms, answer questions, or complete surveys when using any of our Services, when you create an account with us, including your email address, or if you invite your friends to use our Services;
• in certain jurisdictions, we collect your date of birth and/or your age to comply with applicable local regulations;
• location information (State or country level) of your device;
• the content of messages sent using our chat and messaging systems;
• if you contact us, for instance through our customer service channels, or respond to messages and communications that we send to you, we will keep a record of that correspondence;
• your interactions with us on our social media channels;
• information we collect via cookies and other similar technologies, as explained further below;
• information as further set out in this Privacy Policy, including Szone Profile and playing socially, Marketing, and Advertising;
• information we collect about you from our other Group Companies or other third-party companies who have obtained your consent or have another legal basis to share such information with us (including publishing partners, platforms, advertising platforms, and partners and data aggregators). This will include attributes about you and your interests, as well as other Games and Services you use, demographic, and general location information.

We will collect device-level identifiers and other information associated with those identifiers including:

• the type of device(s) you are using to play our Games or access our other Services, identifiers such as IP address, device identifiers, ad identifiers, player ID, and the country or region that you are playing in
• how you play our Games and interact with our Websites or other Services (such as which of our Games you are playing, your progress through the Games, session time and duration, number of attempts at each level, and purchases made).

In some instances, when you make purchases on or through our Websites, we will collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by Szone. Unless otherwise stated we do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful.

When you purchase items in our mobile apps through the App Store, on Facebook or Google Play, or purchase and redeem gift vouchers for our Games, we do not collect or store any payment information from you.

We will from time to time ask you for your consent to collect other information from you or your device. For instance, we will invite you to allow us to access your contacts to enable us to invite them to play our Games with you. If we do this or something similar, we will tell you what information we would like to collect, why we need it, and what we’ll use it for.

We, our partners and Group Companies will use this information:

• to enable us to provide our Games and other Services to you, to ensure that any purchases you make are verified on our servers and activated in the Games, and to provide you with player support if you need it;
• to enable us to optimize our Games for you and for the device that you are using, as well as to deliver customized in-game events, offers, and promotions; for the other purposes as set out in this Privacy Policy, including for Marketing and Advertising purposes; and
• to enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our Terms of Use, or where necessary to defend, exercise, or establish our legal rights including our rights under our Terms of Use (TERMS AND CONDITIONS)

We will also share your information with third-party publishers who develop and provide Games and other Services to you on our behalf.

We analyse and use the information that we collect on a de-identified or aggregated basis for product development, to analyse the performance of our Games, to troubleshoot, and to improve and optimise our Games to ensure the best player experience for our players as a whole.

A more detailed description of some of the ways that we use your information is set out below and in the other sections of this Privacy Policy, including our section containing disclosures for US residents.

Providing and optimising our Services

We use your information to enable us to provide our Websites, advertising, and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include the use and analysis of aggregated data to make sure that our Websites work properly on all devices and are as enjoyable as they can be for all our players.

Chat

Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players, or to Szone customer service. Your messages will be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 30 days your in-game chat messages will no longer be accessible). We reserve the right to monitor and review the content of your messages, in accordance with applicable laws and regulations, including by using automatic filters and/or AI tools, to prevent toxic and abusive behaviours and to ensure that you are complying with our Terms of Use. We also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.

Customer Services

We use your information, including information that you provide directly to us in communications, to provide you with support through our customer service channels at your request when you need it. We will also use this information to contact you, for example as part of customer service or to send you updates about our Services. Finally, we will use your information to manage your account and relationship with us and improve your experience when you use our Services.

One of our customer service channels is the Szone Community website (https://hxg.agency). For information about what information we collect and process when you use the Szone Community website, see Visiting our Websites below.

Analytics and Research

We use analytics tools, which will include third party analytics tools, to collect information about how you play our Games or use our other Services. Those tools will use cookies or other similar tracking technologies. We will use your information to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We will also create reports, analysis, or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content.

Social and Community

We have several social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you. We will also republish your posts to those channels and these will be available to those with access to those channels, which may be public.

Promotions and Competitions

From time to time we will run promotions or competitions during which we will collect certain personal information from you, such as your name, address, post code, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition. We will also publish the names and entries of competition entrants. That information will also be combined with your Sone Profile and other account information and will be processed, stored, and shared in accordance with this Privacy Policy.

QR codes: When you scan a QR code either to invite friends to download any of our Games, or to participate in promotions and similar activities, we will collect information from you, such as your device ID, your location, your unique visitor ID, the device used, IP address, time and date of the scanning. If a third party provides the QR code they will collect this information from you and we encourage you to read their privacy policy to know how they will process your personal information.

Cheating, crime toxic and abusive behaviour, and fraud prevention

We will use personal information that we hold to prevent cheating, crime, toxic and abusive behaviour, or fraud. We monitor our Games and other Services, using different tools, including AI tools, to detect such activities. We will process your personal information to monitor your account for anomalous player behaviour, this will help us to ensure the Game is fair between players.

We will also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police or other public bodies or entities where we are required to do so.

Legal uses

We will use your information as required or permitted by any applicable law. For example, if you live in the European Union, this includes providing VAT invoices where we are required to do so by applicable law or where requested by you.

Visiting our Websites

When you visit our Websites, such as https://hxg.agency, and other Websites operated by us (“Websites”), we collect information about you, such as details about how you use and interact with such Websites. We will use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with our advertising purposes, and for research or analysis.

The information we collect and process about you when you visit our Websites includes:information that you provide us with when you fill in forms or create posts on our Websites, or when you create an account with us on our Websites;

• details of your use of the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);
• if you contact us or respond to messages and communications that we or other users of the Websites send to you, we will keep a record of that correspondence;
• your interactions with us on our social media channels; and
• information which is collected via cookies (which are small text files placed on your device), and other similar technologies. Cookies allow us and Third Parties to collect information, such as your device’s model, operating system and screen size and other information about how you use our Services. For more information, see Ad identifiers, cookies and similar technologies below.

We use this information:

• as necessary in order to provide the Websites and related Services to you;
• for the purposes of contacting you, for example as part of customer service or to send you updates about the Websites;
• for the purposes of managing your account and relationship with us and improving your experience when you use the Websites;
• for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes;
• for the purposes of marketing and promotion of our Games and other Services, for example sending you communications (including by email) for these purposes on our, or a third party’s behalf. For example, we might send you information about merchandise relating to our Games. If you do not want us to use your information in this way please let us know by either opting out within your account, see Opting-out of direct marketing from Szone below or by contacting us via email  marketing@hxg.agency.
• to create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Websites;
• for the purposes of preventing cheating, crime, toxic or abusive behaviours or fraud. We will also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention where we are required to do so; or
• as otherwise expressly set out in this Privacy Policy or as required by applicable law.

When using the Szone Community online forum, please be aware that in addition to your name, any questions, answers, comments or submissions that you post will be publicly available and any data you provide can be read and/or used by other users. You should therefore only share content that you are comfortable sharing publicly

Szone Profile and Playing Socially

You can choose to use a third party social network (such as Facebook) to add information to your Szone Profile or to connect to your account. If you do this, then your personal information will be visible to other players and we’ll also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising.

Szone Profile

When you play our Games either with, or without creating an account, we will give you a randomly generated unique identifier known as a “Szone Profile”. If you choose to create an account this will add your personal information to your “Szone Profile”, such as your first and last name, avatar, email address or other information. We can then identify you with your personal information.

Your Szone Profile and the information it contains will be visible to other users of our Services. If you choose to create an account by adding personal information to your Szone Profile, it will be visible to your friends and other players anywhere in the world.

If you choose to view another individual’s Szone Profile, that individual and other users of our Services will know that you have visited them because some of your social information and a link to your Szone Profile will be displayed on that individual’s Szone Profile.

Connecting with a third party network

Where we make this available, you can choose to log in to your Szone Profile using your account details with a third party network, such as Facebook or Apple. If you do this, you will be able to use your account to log in on multiple devices and synchronise progress across those devices. Where available, you will also be able to see which of your friends are playing the same Game and their progress through the Games (and they will be able to see you and your progress), or access other functionality we make available in our Games and other Services, such as inviting friends to play, asking other players for lives and one-to-one messaging.

Marketing

Where we record your preferences as permitting us to do so, (see further below on how to change your preferences) we and our third-party partners use information collected about you to send you marketing communications about our Games and other Services based on your interests. For example, we will send emails, serve ads within our Services or place ads on third party websites, apps and Internet-connected devices.

We will use the information that we hold about you to promote our Games and other Services in a number of ways. This might include:

• advertising within third party websites, apps and Internet-connect devices;
• showing you promotions for other Szone games in the Games you play; or
• sending you marketing materials by email.

We will use the information that we hold about you to promote our Games and other Services or those of Szone in a number of ways. This might include:

• advertising within third party websites, apps and Internet-connect devices;
• showing you promotions for other Szone games in the Games you play; or
• sending you marketing materials by email.

What information do we use for marketing?

We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we will have about you, such as:

• ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
• the Games you play and information about how you interact with our Games and other Services;
• your age, country or region, and gender; and
• other information that we collect from you or might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal basis to share that information with us.

Marketing partners

When we market our Games in media published by other companies, we use various third-party marketing partners to assist us on our behalf, and we will share information which we have collected about you with such third parties for these purposes.

Our marketing partners will help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for our Games or other Services, they will serve you with a Szone ad while you are using other websites and services.

By accepting this Privacy Policy and downloading or continuing to play our Games, and unless you opt out of targeted advertising as explained in this section, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies.

This Privacy Policy does not apply to the collection of your information by our marketing partners. We recommend that you review our partners’ privacy policies for more information. 

Opting-out of direct marketing from Szone

You can exercise choices over the direct marketing we send you in the following ways:

• you can give your consent for us to send you direct marketing emails by opting in when we collect your email address or by choosing not to share your email address with us;
• you can remove yourself from receiving email marketing from us at any time by simply clicking the unsubscribe link in any direct marketing email we send to you or by contacting the player support team. If you have chosen to receive more than one type of marketing communications from us, you will need to opt out of all of them individually. It will take a few days for us to update our records before any opt out is effective; and

You should note that if you opt out of receiving targeted advertising, you will still see advertising and you will see advertising for Szone products, but that advertising will not be targeted using your personal information.

Advertising

Our Games include advertising for third party products and services.

Szone and our advertising partners collect and use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our Games.

Szone participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Szone uses the Consent Management Platform (CMP) with the identification number 28.

Where applicable, we use a CMP to gather consent and permissions for our advertising based activity. Where local laws allow, we will opt you into targeted advertising by default. You can change your preferences at any time in the Privacy and Security settings of our Games.

We use information that we hold about you to better target ads for third party goods and services to players that might be most interested in them. These ads will be shown to you within our Games or Services.

What information is used for advertising?

We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our Games that might be of interest to you. This includes information such as:

• ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
• the Games you play and information about how you interact with our Games and other Services; and
• your age, country and region, and gender; and
• other demographic and interests-based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.

Advertising partners

When you play our Games or use our other Services, identifiers and other information from your device is collected and shared with our advertising partners to enable the technical delivery of ads to your device.

Our advertising partners will combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our Games or to improve the accuracy of their targeting and measurement systems.

If you consent to, or are opted into, the collection and use of your data for targeted advertising purposes by our advertising partners your information will be used as set out in this section and as further described in our partners’ privacy policies. We recommend that you review our advertising partners’ privacy policies for more information. A list of our advertising partners and their Privacy Policies can be found here. You can refuse or withdraw your consent to such use at any time.

How to adjust your preferences for targeted advertising

You can choose to prevent your device’s ad identifier being used for interest-based advertising (referred as “personalised ads”, “cross-contextual ads” or “targeted ads”) by updating the settings on your device.

When we record that your preference is not to be shown targeted advertising, you will still be able to play our Games and you will still see advertising in our Games, but those ads will not be targeted using information that we or our advertising partners hold or collect about you. However, you will still receive ads based on criteria such as the Game you are playing, the content of that Game, or the region in which your device is located.

Players in the United States should review the US residents section to know more about the sale and sharing of personal information and options available to residents of some states.

For players outside the US: If you would prefer that your personal information is not processed to receive targeted ads in a particular Game, you can update your preferences via the Privacy and Security setting in that Game. You can also submit an opt-out request for all of our Games. Please note that outside of US states with applicable privacy laws, even if you have opted-out of targeted ads in our Games, you may still receive targeted ads from Facebook. If you would prefer that Facebook does not use your personal information for targeted ads, you need to log into your Facebook account and update your settings there.

Opting out of targeted advertising at device level: You can choose to prevent your device’s ad identifier being shared and used for targeted advertising by changing the settings of your device. On some devices it may be possible to reset your device’s ad identifier. Settings vary from device to device but you will usually find the ad identifier settings under “Privacy”, “Tracking” or “Ads” in your device’s settings. If you live in the USA, the EEA or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for EEA users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).

Ad identifiers, cookies and similar technologies

To provide our Games and other Services, Websites and targeted advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.

Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and to collect information from your device. For example, these technologies allow us and our third party advertising partners to:

• recognise you and your device;
• provide targeted advertising to you;
• allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
• allow us to understand how you interact with our Websites (for example, where we use cookies such as the Google Analytics cookie on our Websites);
• allow our payment processors to process your payment instructions; and
• enable us and third parties to provide you with more customised services, for example to provide our Services in the correct language.

How do ad identifiers, cookies and similar technologies work?

Ad identifiers are identifiers such as the Android advertising ID and/or Apple’s ID for advertisers (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser or by using the cookie settings on our Websites.

Your rights

You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below. Users located in the United States should review the US residents section below.

Those rights include:

• Right of access. You have a right to know what information we hold about you and in some cases to have that information communicated to you. If you wish to exercise this right please contact us. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we will not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why.
• Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please contact us and we will correct it as soon as we can.
• Right of erasure. You have a right to request to have some of the personal information that we hold about you deleted. Please note that in order to process your request you must delete our Games from your mobile devices and clear our cookies from any device where you have played our Games in a web browser. Where we delete personal information about you, we will still retain some, or all, of that information for other purposes such as maintaining financial records, protecting, or enforcing legal rights, maintaining marketing suppression lists or for technical reasons. In addition, we will also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores, and any chat messages will be cached on other players’ devices and we will not be able to remove or update that information from those devices, for example if that device is not connected to a wifi network.
• Account deactivation. If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We will ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile Games and deleting our Games from your mobile devices. Please note that if you completely deactivate your account all your progress in our Games and any unspent virtual items, such as Gold Bars or Boosters will be lost, and we will not be able to restore them in the future.
• Data portability. In some circumstances, you will have the right to request that your personal information is provided to you so you can transfer this to another data controller.
• Restriction of processing. In some cases, you will have the right to request a restriction of the processing of your personal information, such as when you are disputing the accuracy of your data held by us.
• Right to object. You have the right to object to the processing of personal information about you which is processed on the grounds of legitimate interests.
• Direct marketing opt out. If you have chosen to receive direct marketing communications from us, you can change your mind at any time see the section above Opting-out of direct marketing from Szone.
• Right to opt-out (USA): Virginia, Colorado, Connecticut and Utah residents have the right to opt out of targeted advertising. When you opt out of targeted advertising, you might still see ads which are not personalised for you. California residents have the right to opt out of the sale or sharing of personal information, which is defined in a way that will include the transfer of data to third parties to personalise ads for you. If you opt out of the ‘sale or sharing’ of your information, we will not sell your information, including to our advertising partners, or share your information with them, but you will still see ads in the Game and some of our partners will deliver ads to you, based on information they hold on you. See How to adjust your preferences for targeted advertising for more information.There are other ways in which you can control the personal information that we collect about you. For instance, you could disconnect your Facebook or other social network account from our Games, or delete our Games from your mobile device. You could also limit ad tracking altogether using the settings in your phone. Finally, you could limit or prevent the use of cookies in your web browsers. More information on all of these options is provided elsewhere in this Privacy Policy.
• Right to lodge a complaint to the supervisory authority (EEA/UK/Canada): We hope that we can satisfy queries you may have about the way we process your personal information. If you would like to discuss something with us, please contact us using the details below. However, if you have unresolved concerns you also have the right to complain to data protection authorities. You can bring the complaint in your province, country or member state of residence, place of work or where an alleged infringement of data protection law occurred.

Residents of some US states may also designate an agent to make requests to exercise your rights as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.

Children

In accordance with our Terms of Use you must be over a certain age to play our Games and use our Services, depending on where you live. For the full list of age restrictions by country, please see below. We do not knowingly collect or solicit personal information from or direct or target interest-based advertising to anyone under the ages set out below or under 16 for California residents, or knowingly allow such persons to use our Games and Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us

The table below sets out what age you must be to play our Games and use our Services, depending on what country you are in while using our Games and other Services. Our Games are intended to be played by adults and we do not knowingly collect, and do not wish to collect, information about children. Please do not play our Games or use our other Services if you are under the relevant age.

Country	Age you must be to play our Games and use our Services
Austria	14
Belgium	13
Bulgaria	14
Canada	13 outside Quebec; 14 in Quebec
Croatia	16
Republic of Cyprus	14
Czech Republic	15
Denmark	13
Estonia	13
Finland	13
France	15
Germany	16
Greece	15
Hungary	16
Ireland	16
Italy	14
Latvia	13
Lithuania	14
Luxembourg	16
Malta	13
Netherlands	16
Norway	13
Poland	16
Portugal	16
Romania	16
Slovakia	16
Slovenia	15
South Korea	14
Spain	14
Sweden	13
Switzerland	16
United Kingdom	13
Rest of the world	13

If you believe that we might have any information from or about a child under the relevant age set out above, please Contact Us. In the event that we learn that we have collected personal information from a child under the relevant age set out above, we will delete that information as quickly as possible.

General

This Privacy Policy contains further details about:

• who we share your information with and the reasons for sharing it;
• measures we take to keep your information secure;
• the legal basis under which we process your information;
• how long we retain your information and where we store it;
• when and why we share your information with third parties, including transfers outside of the European Economic Area (the “EEA”), the UK, Switzerland and Canada (including Quebec); and
• changes or updates to our Privacy Policy.

Sharing

In addition to what is described in this Privacy Policy, we will also share your information:  

• with the various Group Companies, including for the group companies’ own marketing purposes;
• with third-party partners and licensees engaged by Szone to provide you with goods or services you have requested;
• where we have your consent to do so (including as set out in this Privacy Policy);
• as reasonably necessary in order to provide our Services to you (for example, by providing your personal information to partners we use to fulfil the Services or to communicate with you);
• where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment partners);
• where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
• where we reasonably believe it is permitted by applicable law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; to exercise, establish or defend our legal rights or
• where it is necessary to protect the rights, property, or safety of any person and of Szone, Szone’s personnel and users; and
• if there is a sale of the assets of Szone or corporate restructuring, or as a result of a change of control of Szone or one of its Group Companies, or in preparation of any of these events. Any third party to which Szone transfers or sells Szone’s assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

We will also share your information with our Service Providers if necessary to enable them to provide services to us.

Any information, including personal information you reveal in a bulletin board, message board, chat room or other public forum is publicly viewable.

Security

Szone takes appropriate security and technical measures to protect your information from unauthorised access, loss and misuse. In addition, we request that our partners who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. In addition, we request vendors who process personal information on our behalf to take a range of security measures designed to help protect your personal information. However, we cannot guarantee the absolute security of your information online and offline, as the internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.

Szone maintains and keeps your personal information confidential, unless it is not confidential by nature, for example publicly-available information like user generated content, leaderboard rankings and scores, etc or information that you post or publish on your social media.

Legal Basis

In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal basis which we rely upon are the following:

• Contractual Necessity and performance of the Games and other Services. We process your personal information for the performance of our Games and other Services, to provide or support of our Games and other Services, or for any other feature you request or enable. This includes using your personal information, for example, to:
  • provide you the Games and other Services you have requested;
  • support game functionality, such as chat functionality or third-party social network connectivity;
  • support purchases you made;
  • administer your Szone profile or account;
  • provide global customer service; and
  • provide a fair gaming experience by using anti-fraud technologies such as bans or blocks of accounts.
• Legitimate Interests. We process your personal information where we have a legitimate interest to do so. This includes the processing of your personal information, for example:
  • Marketing and Advertising of our Games and other Services;
  • Analytics, research and optimisation of our Games and other Services;
  • Debugging and improving our current and future Games and other Services;
  • Give exclusive content, personalise your online experience with us;
  • Contact you in accordance with applicable marketing preferences; and
  • For the establishment, exercise or defence of legal claims.
• Consent. We process your personal information based on your consent, for example, when you consent to:
  • enable targeted advertising in our Games;
  • the storage of information on your device by us and our advertising partners, including through the use of cookies and other trackers;
  • receive newsletters, direct e-mails and surveys about our Games and Products that may be of interest to you;
  • enable certain other marketing features;
  • sharing data with our partners or Group Companies.
• Where we ask for your consent to use your information for any other purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent.
• Legal Obligation. We process your personal information for compliance with a legal obligation to which we are subject, such as to maintain records relating to tax or to respond to a valid legal request for certain data.

In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our Games we will still collect some personal information about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal information about you at all, you should cease playing our Games and stop using our Services.

Retention

We will keep your information for as long as your account is active or we consider necessary for the purposes described in our Privacy Policy. We will also retain and use your information for as long as is required in order to comply with our legal obligations.

Location of storage

We store your information on servers that we control some of which are based in the EEA and UK. We will also use servers and engage providers that are located outside the EEA and UK in order to process and store your information and to provide services to us.

International Transfer

We may transfer your information to Group companies or third parties in jurisdictions outside of where you live, including outside of the EEA, the UK, Switzerland, Canada (including Quebec), such as the United States. Please note that these jurisdictions will not have the same data protection laws as your jurisdiction and there may be legal means for courts, law enforcement and national security authorities in those jurisdictions to require access to your information. We take steps to ensure that there are adequate safeguards and mechanisms in place (for example, the use of EU model clauses) to allow the transfer of your information across borders outside of your jurisdiction.

South Korea

Please note that a different version of this Privacy Policy applies if you live in South Korea (please see https://hxg.agency/p-p-vi/).

Changes to this Privacy Policy

We will update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us unless we provide otherwise.

US residents

In addition to the information provided throughout this Privacy Policy, state privacy laws in the United States require that we disclose to consumers in those states additional information about the processing of their personal information. Below we describe the purposes for which we use and disclose personal information and, for each purpose, the categories of personal information we use and disclose and the categories of third parties to whom we disclose the personal information.

• Service functionality: We use certain information to provide you with our Services, including to create and manage your account, enter a contract for sale or services, facilitate purchases or process payments, fulfil orders, send service communications, provide customer service functions, and conduct general business operations, such as accounting, recordkeeping, and audits, analysing our performance, and meeting our legal obligations.
• Service improvement: We use information you provide to improve, grow, and optimize our Services, including to maintain and verify the quality of our Services, develop new Games, products, and other services, and understand how our Services are being used, our customer base and purchasing trends, and the effectiveness of our marketing.
• Personalisation: We use information to offer you recommendations and tailor our Services to your preferences. The personal information we collect and use for these purposes includes:
  • Personal information provided by you:
    • Contact information, including name, username, date of birth, email address, telephone number, avatar or profile picture
    • Demographic information including your date of birth, and country
    • Payment information, collected by our third-party payment processors to complete a purchase or provided by you to our Customer Service
    • Information that you provide when you register with a Service, including when you link a third-party account to your Szone Profile or play via a third-party account (such as your Facebook account)
    • Information contained in your communications to us, including when you contact our customer service
    • Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services)
    • Customer service information, such as any issues you raise and their resolution
    • location information (State or country level) of your device
    • Information of contacts that you supply to us, may be shared with our service providers. We do not sell or share such information
  • Personal information automatically collected:
    • Websites visited before and after you use a Service
    • Browser type and language
    • IP address
    • Hardware and software information
    • Gameplay data
    • Communications
    • Usage data
    • Purchase history
• We disclose this personal information to:
  • Various Group Companies which may use the personal information for their own marketing purposes
  • Service providers, including billing firms, customer service support, consultancies, information technology providers, cybersecurity providers, payment processors, accounting and auditing firms
  • Partners and licensees who provide you with goods or services you have requested, or create applications and websites that benefit our player community
• Szone also publicly displays certain personal information about you, including third-party account information and gameplay information, on our Services, or the properties operated by our third-party partners and licensees.
• Sweepstakes, Promotions and Competitions: When Szone runs promotions or competitions, we collect certain personal information from participants to enter them into the promotion and to deliver any prizes won. We will also need to collect additional information in order for you to claim a prize. We will combine that information with other information we have collected about you and use such combined information for other purposes stated in this Privacy Policy. The personal information we collect and use for these purposes includes:
  • Personal information provided by you
    • Contact information, including name, address, postal code, age and/or date of birth, email address, telephone number, and other information you submit
    • Information you provide in order to claim any prizes you win
• We disclose this personal information to:
  • Various Group Companies which may use the personal information for their own marketing purposes
  • Service providers, vendors, or business partners, such as entities conducting promotions on our behalf. In some circumstances, such as disclosures to business partners are for their own marketing purposes, however, we make these disclosures only with your consent.
• Advertising and marketing: To send you marketing communications and newsletters, personalise the advertisements you see on our Services and third-party online properties, and measure the effectiveness of our advertising The personal information we collect and use for these purposes includes:
  • Personal information provided by you:
    • Contact information, including name, username, date of birth, email address, telephone number
    • Demographic information including your, date of birth, and country
    • Information that you provide when you register with a Service, including when you link a third-party account to your Szone Profile or play via a third-party account (such as your Facebook account)
    • Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services)
    • Information about your interests in and use of various products, programs, and services
    • Marketing preferences
  • Personal information automatically collected:
    • Websites visited before and after you use a Service
    • Browser type and language
    • IP address
    • Hardware and software information
    • Gameplay data
    • Communications
    • Usage data
    • Purchase history
    • Mobile advertising IDs, non-personal identifiers, and other information from your mobile device
• We disclose this personal information to:
  • Various Group Companies which may use the personal information for their own marketing purposes
  • Online advertising partners, including partners who use Cookies to personalize, retarget, and measure the effectiveness of advertising, including on our Games
    • These partners will combine this personal information with information that they have collected about you when you use their services (or the websites and services of third parties) to serve you more relevant ads or to improve the accuracy of their targeting and measurement systems.
  • Social media platforms
  • Business partners, when you give us your consent to disclose your personal information to them
• The personal information we collect and use for these purposes includes:
  • Personal information provided by you:
    • Contact information, including name, username, date of birth, email address, telephone number
    • Information that you provide when you register with a Service, including when you link a third-party account to your Szone Profile or play via a third-party account (such as your Facebook account).
    • Any information that you provide by interacting with our Services (please note that some comments or information will also be visible to other users of our Services)
  • Personal information automatically collected, including by monitoring and recording on your device:
    • Websites visited before and after you use a Service
    • Browser type and language
    • IP address
    • Hardware and software information
    • Gameplay data
    • Communications (including without limitation chat, text, or voice communications)
    • Usage data
    • Mobile advertising IDs, non-personal identifiers, and other information from your mobile device
    • Activities on your device
• We will disclose this personal information to:
  • Various Group Companies which will use the personal information for the purposes listed above
  • Service providers such as platform providers, cybersecurity providers, tournament providers, and information technology providers
  • Other entities when we believe that this is necessary to protect the rights, property, or safety of any person
  • Regulatory or law enforcement agencies
• Legal compliance: To comply with legal process, such as warrants, subpoenas, and court orders; to respond to lawful regulatory or law enforcement requests, such as when we have a good-faith belief that we must do so by applicable law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or will expose you or us to legal liability; to exercise, establish, or defend our legal rights; to protect the vital interests of any person; and to comply with applicable legal requirements. Such personal information includes:
  • Any information requested through legal process or that we believe in good faith is necessary to respond to lawful regulatory or law enforcement requests for the purposes listed above. We will disclose this personal data to:
    • Regulatory or law enforcement agencies, including jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
    • Our legal advisors or consultants.
• Corporate change: We will disclose any personal information that we have collected about you in connection with the sale of our business or assets in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event.

Szone is not responsible for the privacy practices of its Group Companies and the use of your personal information by its Group Companies will be governed by those specific companies’ privacy policies, which you will find on each company’s website.

Your US Privacy Rights

Residents of some states have certain rights in relation to their personal information. We describe below the rights that will be available to you, depending on your state of residence.

Right to Request Access to Your Personal Information

You may have the right to request, up to two times in a 12-month period, access to the personal information we have collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. Please note that certain information will be exempt from such requests under applicable law.

Right to Request Correction of Your Personal Information

You may have the right to request that in certain circumstances we correct personal information that we have collected about you. Some information will be exempt from such requests under applicable law.

Right to Request Deletion of Your Personal Information

You may also have the right to request that we delete personal information that we have collected from or about you. Some personal information will be exempt from such requests under law. For example, we need certain types of personal information so that we can provide our Properties to you. If you ask us to delete it, you will no longer be able to access or use our Properties.

Limit Use of Your Sensitive Personal Information

California residents have the right to limit our use of their sensitive personal information if we use such personal information to infer characteristics about them. It’s your right to limit our use of such personal information is subject to exception. In some states, we will be required to obtain your consent before collecting your sensitive personal information.

Sale and Sharing of Personal Information; Targeted Advertising; Profiling

Under the laws of some states, consumers have the right to opt out of the sale of personal information or the sharing of their personal information with third parties for targeted advertising (also known as cross-context behavioural advertising or interest-based advertising).

We share certain information with third parties who do work on our behalf for the business purposes we describe above.

We also will allow third-party advertising companies to collect information about your activity on our Websites and in our Games and other Services for example through cookies, mobile ad identifiers, pixels, web beacons and social network plugins. These advertising entities use information they collect to help us provide more relevant advertisements and for other purposes described in our Privacy Policy. You can control the sharing of your personal information for targeted advertising through our Websites and Games and other Services in the following ways:

• To set up cookie controls and opt-out of advertising cookies, including third-party advertising cookies.
• You can also set up cookie controls through many browser settings and you can use industry-wide opt outs to control the use of cookies for interest-based advertising purposes.
• You also can opt-out through the in-app Privacy and Security section in our Games. Once you opt out, we record your preferences. We will not share your information for these purposes.

The personal information collected through these methods is associated with your browser or device, so if you would like to opt out for this information you will need to disable cookies or trackers as described above. Because your opt-out preference is stored in a cookie, if you reset your advertising ID or clear your cookies then we will not recognise your device or your choices, so you must opt out again. You will also disable non-advertising cookies through your browser or device settings.

Szone recognises Do Not Track settings.

Personal Information Collected Through Szone Profiles: In addition to the opt-outs related to advertising above, we support state privacy laws by allowing residents to opt out of any other future sale or sharing of their personal information for targeted advertising. You can also submit a request to opt out of sales by emailing us marketing@hxg.agency.

How to Exercise Your Access, Correction, and Deletion Rights

You will exercise any privacy rights to which you are entitled by submitting your request to us via website or sending an email to marketing@hxg.agency. To exercise your right to correction, please update your account information directly or send an email to marketing@hxg.agency.

For security purposes, we will verify your identity – and will request information from you to do so – when you request to exercise your privacy rights. If you have an online account you use to interact with Szone, logging into your account will serve to verify your identity and request. We will request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, then we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

Some states permit you to designate an agent to make requests to exercise your rights as described above. We will take steps to both verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorised to make a request on your behalf through providing us with a signed written authorisation or a copy of a power of attorney.

Once we have verified your identity (and your authorised agent, as applicable), we will respond to your request as appropriate. If we are unable to complete your requests, we will provide you information about the reasons that we could not comply with your request.

Profiling

We do not engage in “profiling” in furtherance of decisions that produce legal or similarly significant effects.

Right to Non-discrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights, unless allowed under applicable law.

Appeals

Some state laws allow residents who are not satisfied with our response to their requests to appeal our decision by contacting us as described in the written notice we will provide to you.

Additional Privacy Information for California Residents

Depending on how you interact with us, Szone will collect the following categories of personal information about you. For information about the purposes for which we use and disclose data, and additional potential disclosures of personal information, please see US residents section above.

• Identifiers, collected from you, on our social media pages, or third-party subscription service providers, will be disclosed to our service providers and will be sold to or shared with business partners.
• Financial information, collected from you, will be disclosed to our service providers. We do not sell or share financial information.
• Protected classifications and other sensitive information, collected from you, will be disclosed to our service providers. We do not sell or share protected classifications and other sensitive data.
• Commercial information, collected from you, will be shared with our service providers. We do not sell or share commercial information.
• Geolocation information (location at State or country level only), collected from you and our analytics and advertising partners, will be shared with our service providers. We will sell or share coarse location information to our advertising partners; we do not sell or share precise geolocation information.
• Internet or electronic network activity information, collected from you and our analytics and advertising partners, will be shared with our service providers and will be sold to our advertising partners.
• Audio, electronic, visual, thermal, olfactory, or similar information, collected from you, will be shared with our service providers. We do not sell or share such information.
• Inferences drawn about you, collected from you and our advertising and analytics partners, will be shared with our service providers. We will sell or share such information with our advertising partners.
• Content of communications, collected from you, will be shared with our service providers. We do not sell or share content of communications.
• Information of contacts that you supply to us will be shared with our service providers. We do not sell or share such information.

We determine the retention period for each of the categories of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.

California residents have the right to opt out of the sale or sharing of their personal information, as explained here.

We will collect your personal information in order to offer you the benefits and rewards you request. If we offer you the chance to participate in a specific program, your participation is optional. If you choose to participate, your participation will be subject to the applicable terms or conditions, and you can withdraw at any time. Your information has no real currency value or its equivalent.

California Shine the Light Law

Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer’s personal information with third parties for their own direct marketing purposes, without their approval. For inquiries regarding our disclosure policy, please send us an email to marketing@hxg.agency.

California Privacy Rights for Minor Users

Since January 1, 2015, California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or remove information provided by you or publicly posted by you, by accessing your Szone Profile or another product or service as applicable and editing/removing your information. You will need your password to access your personal account. You may also send us an email asking us to remove certain posted content at marketing@hxg.agency. We will be happy to review, update or remove information and/or content as appropriate. Residual copies of information and/or content that have been removed from your account and/or the Services will remain in our backup systems. We will still retain your information to resolve disputes, enforce our Terms of Use or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose.

Additional Privacy Information for Nevada Residents

Under Nevada law, Nevada residents who have purchased goods or services from us will opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and service of interest to you and in the other ways described above. We do not believe that our sharing in this regard would qualify as a sale under Nevada law. Nonetheless, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to record your preference to opt out by emailing us at marketing@hxg.agency. Please note we will take reasonable steps to verify your identity and the authenticity of the request.

Contact us

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several ways of contacting us:

1. via our customer service page at https://hxg.agency/;
2. via email to marketing@hxg.agency; or
3. in writing to Szone Studio at 2nd Floor, B Tower, Central Buiding, 219 Trung Kinh, Cau Giay, Ha Noi, Viet Nam.