At IGW, we value your understanding of the information we collect and how it is utilized. We highly recommend reviewing our Privacy Policy to ensure that you can make informed decisions while using IGW Products. Our Privacy Policy provides detailed explanations on how we gather, employ, disclose, store, and transfer information. Additionally, we outline your rights in a clear and comprehensible manner throughout the Policy. We have included helpful examples and simplified language in each section to enhance your understanding of our practices.

1. Information We Collect

The information we gather consists of Personal Information, which refers to any details about you that reveal or reasonably allow the determination of your identity, regardless of its accuracy. When anonymous information is connected to personal information, the resulting data is also treated as Personal Information. Anonymous information, on the other hand, refers to information that does not directly or indirectly identify an individual and cannot reasonably be used to do so. Aggregate information pertains to data about groups or categories of customers that cannot identify an individual customer.

1.1 Personal Information

Personal Information refers to any information that relates to a person and can be used to identify them. The Personal Information you provide to us generally includes contact details (name, email, phone number, address), login and account information (unique user ID and password), personal details (date of birth, purchase history), and personal preferences (wish list, marketing preferences).

The Personal Information we collect may include:

• Contact Details: Such as your name, email address, postal address, and phone numbers.
• Account Information: Such as unique user IDs, passwords, and account preferences.
• Transaction Data: Details of transactions made within the game, including payment method, amount, date, and time.
• Social Network Data: If you connect via a social network, we may collect data from your profile, such as your name, profile picture, and friend lists.
• Customer Support Interactions: Records of your interactions with our customer support team, including chat logs, call recordings, and email correspondence.
• Communication within the Game: In-game chat logs and messaging between players, if applicable.
• Mobile Device Identifiers: Unique device identifiers such as IMEI numbers are used for mobile applications.

We collect Personal Information directly from you in the following instances:

• Making an online purchase.
• Sending us emails or other communications.
• Joining our social networking sites.
• Registering for an account.
• Participating in promotions, surveys, and contests.
• Playing our social games.
• Participating in sweepstakes.

1.2 Anonymous Information

Anonymous Information is data that cannot be used to directly or indirectly identify an individual. For example,

• The number of players who won a certain game within the last week without associating this data with specific user accounts is anonymous information.
• Include statistical data regarding the number of visitors to our site or application.

1.3 Automated information

Automated Information is data collected automatically through technology without direct human involvement. For example, when you visit our platform and browse through products, we may use cookies to track your activities, such as the pages you visit, the items you view, and the links you click. This information is gathered without you actively providing it.

Our website collects information through automated means to enhance your experience. Below is an overview of the types of information we collect:

• Device and Connection Information: Includes your IP address (which can indicate your location), unique device identifiers, and the device’s internet connection.
• Browser and System Preferences: We collect data regarding your browser type, device characteristics, operating system, and language preferences.
• Navigation and Interaction Data: This encompasses the URLs that led you to our site, the pages you visit, the actions you take, and the dates and times of your visits.
• Cookies: Our site uses cookies, which are small files stored on your browser. They help us in gathering data about your preferences and interactions. You can disable cookies through your browser settings, but this might affect the site’s functionality.
• Email Interaction: We may include “click-through URLs” in our emails that, when clicked, pass through our server and allow us to track your engagement. To avoid this, you can choose not to click on links within our emails.
• Third-Party Data Collection: External entities might also collect information via our site for advertising purposes through cookies, plugins, and widgets.
• Clickstream Information: Our server records data about your navigation patterns, such as the pages you visit and the search terms you use on our site.

1.4 Aggregate Information

Aggregate Information is created by pooling Anonymous Information and, in some cases, Personal Information, and is used to analyze trends, improve our services, and enhance the user experience.

1.5 Data Combination

We may combine data collected through automated means with personally identifiable information to provide personalized services, game recommendations, or promotions based on your behavior and preferences.

1.6 Opt-Out Choices and Security Measures

You have options regarding the collection of certain information. For example, you can choose to disable cookies or opt-out of email tracking. However, note that doing so may affect the functionality of our services. We employ security measures such as encryption and firewalls to protect the data we collect.

Please understand that while we strive to protect your information, no security system can prevent all potential security breaches.

By using our services, you acknowledge and agree to the collection and use of information in accordance with this policy.

2. How We Use Collected Information

The Data Controller is accountable for using your information for the business purposes outlined in this Privacy Policy. Other members of the IGW Group may access this information when acting on behalf of the Data Controller as data processors.

2.1 Basis for Using Personal Information:

We use your Personal Information in the following scenarios:

• Contractual Obligations: Such as obtaining various professional services in relation to our offerings.
• Compliance with GDPR and EU Laws: To abide by the relevant legal requirements.
• Legitimate Interests: Such as investigating violations of this Privacy Policy and protecting our rights and property.
• Your Consent: You may grant and have the option to withdraw at any time.

2.2 Sharing Personal Information with Third Parties:

• Service Provision and Management: Such as processing your personal details to respond to your queries.
• Improving Customer Service and Services: Your information aids in efficiently addressing your service requests and helps us enhance our products and services based on your feedback.
• Personalizing User Experience: Aggregated information helps us understand how users engage with the services and resources on our Website.
• Communication: To keep in touch with you, maintain relationships, and process your requests or complaints.
• Sending Important Notices: Includes communications about purchases or legal notices about changes to our terms and policies. You may not opt-out of these essential communications.
• Legal and Regulatory Compliance: Your information may be used to comply with laws, and regulations, and to protect or exercise our legal rights.
• Automated Decision-Making: We do not engage in automated decision-making as defined by global data protection laws.
• Business Negotiations: Personal Information may be shared during business negotiations, such as seeking investors, mergers, or sales of assets.
• Legal Compliance and Cooperation: We may disclose your Personal Information when legally required or cooperate with legal proceedings.

2.3 Targeted Advertising and Data Collection:

• Partnership with Third-party Advertisers: We collaborate with third-party advertisers for targeted advertising, employing remarketing and retargeting strategies.
• Customized Ads: Ads for our products/services are tailored based on your interests and displayed across various websites and mobile applications.
• Data Collection Methods: Third-party advertisers use automated tools like cookies, web server logs, and web beacons to track your online activities.
• Information Gathered: Data collected includes information on your visits to websites and mobile applications within relevant advertising networks.
• Marketing Analysis: The tracking process also helps us evaluate the effectiveness of our marketing efforts.
• Opting Out: Some third-party advertisers are part of the Network Advertising Initiative, which allows you to opt out of targeted advertising from its members at www.networkadvertising.org.
• Note for California Residents: If you are a resident of California, please see the “Privacy Notice for California Residents” for additional details.

2.4 Links to Other Websites:

• Presence of Third-party Links: Our Sites may include links to third-party websites.
• No Endorsement: Inclusion of links doesn’t imply endorsement of the third-party websites or their offerings.
• Independent Privacy Policies: Third-party websites have their own privacy policies, and our Privacy Policy does not apply to them.
• Our Limited Control: We have no control over third-party websites, their content, or how they manage data.
• Responsibility for Data Sharing: If you share personal information on third-party websites, you are subject to their privacy policies.
• Third-party Apps Connection: If you use third-party apps (e.g., Facebook, Twitter) to access our Sites, their privacy policies govern your activities on those platforms.

3. Your Privacy Rights and Choices

You have the right to control how your personal information is used:

3.1 Marketing Communications

If your personal information is used for direct advertising or profiling associated with advertising, you have the right to object at any time. In response to your objection, we will cease processing your personal information for direct advertising.

3.2 Opting Out of Commercial Messages

You can opt-out of receiving commercial messages by following the instructions in those messages.

3.3 Cookies and Tracking

You have the choice to change preferences regarding cookies and other trackers at any time through the “Your Privacy Choices” link on our website. Additionally, you can set your browser to refuse or alert you about cookies, though this might affect certain site features.

3.4 Promotional Offers

You can opt-out of email promotional offers by emailing privacy@igw.com or by clicking the “unsubscribe” link in the emails.

3.6 Interest-Based Advertising

You can opt-out through platforms like TRUSTe’s Ad Preference Manager, the Digital Advertising Alliance’s consumer choice page, or the Network Advertising Initiative.

3.6 Interest-Based Advertising

Our site uses Google Analytics. You can prevent Google Analytics from using your information by adjusting browser settings or using deactivation add-ons.

Note:

• Opting out of promotional communications or advertising does not affect service-related communications.
• Opting out of advertising does not stop the collection of some data for operational purposes.

Please ensure that you understand the privacy practices of third-party websites or applications before providing them with any Personal Information. Also, be informed that settings and opt-outs need to be done for each browser or device separately.

4. How We Protect Your Information

We take the security and protection of your information seriously. Here are the measures we have in place:

• Physical, Electronic, and Operational Procedures: We have implemented physical, electronic, and operational procedures to safeguard the information we collect. These measures help protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Website.
• Data Collection, Storage, and Processing Practices: We adopt appropriate practices to ensure the secure collection, storage, and processing of your data. This includes using industry-standard security measures and regularly reviewing and updating our security protocols to keep pace with technological advancements.
• Mitigating Misuse, Interference, and Unauthorized Access: We employ reasonable means to prevent the misuse, interference, or loss of your personal information. We also have measures in place to guard against any unauthorized access, modification, or disclosure of your data.
• Notifiable Data Breach: In the event of a notifiable data breach, where we believe there has been unauthorized access to your personal information that may result in serious harm, we will comply with legal requirements to notify you of the breach. We will also take necessary steps to contain and investigate the data breach.

Please be assured that we continuously review and enhance our security practices to protect your information from unauthorized access and maintain the integrity of our systems.

5. Protection of Children’s Information

We are committed to safeguarding the privacy of children. The Sites are not intended for use by individuals under 18 years of age, and we do not knowingly permit such persons to use the Sites. Furthermore, we do not knowingly collect, use, or disclose Personal Information from anyone under 18 years of age. If it comes to our attention that Personal Information has been inadvertently collected from a child under the age of 18, we will take reasonable steps to promptly delete such information from our records.

6. Retention and Erasure of Personal Information

We will retain your Personal Information only as long as is necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. Once your information is no longer needed for the purposes for which it was collected, or if there are no legal requirements mandating its retention, we will take reasonable steps to either destroy or permanently de-identify the information. Additionally, you have the right to request the erasure of your personal data, provided there are no compelling reasons for its continued processing. This right is not absolute and applies only under specific circumstances. If you wish to request the erasure of your personal data, please email privacy@igw.com.

7. Changes to this Privacy Policy

We reserve the right to modify or update this Privacy Policy from time to time. Any changes will be effective when we post the revised policy on our website. We encourage you to review this Privacy Policy periodically for any updates. Your continued use of our services after the posting of any changes indicates your acceptance of the revised Privacy Policy.

• Policy Updates and Notifications: We may update this Privacy Policy to reflect changes in our practices or regulatory requirements. For significant changes, we will notify you and, if required by law, seek your consent. Notifications may be made through postings on our website or other means compliant with applicable laws.
• Effective Date of Changes: Changes to the Privacy Policy are effective upon posting the updated policy on our website.
• Staying Informed: We encourage you to regularly check this page to stay informed about how we protect the personal information we collect.
• Supersession of Previous Policies: The Privacy Policy in effect as of the last modified date stated below supersedes and replaces all previous Privacy Policies.

8. Confidential Information

Please refrain from sending any confidential or proprietary information to us via email or other means. Any content such as information, materials, suggestions, ideas, or comments submitted to us will be deemed non-confidential. By submitting these to us, you grant us unrestricted rights to use, modify, reproduce, transmit, display, and distribute this content for any purpose, without any form of compensation to you. We will not disclose your name in connection with this content unless legally obligated or with your prior consent.

9. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your information, please contact us at:

IGW
1333 Corporate Drive Suite 318
Irving, TX 75038
hello@igw.global

We will address your inquiries promptly and in accordance with applicable privacy laws. Changes to this Privacy Policy.

10. International Data Transfers and Consent

The IGW Group has a global presence and operates in various international jurisdictions. Consequently, the personal information we collect might be transferred, stored, and processed by individual companies within the IGW Group or third parties across different countries, including the European Union, the United States, Canada, Australia, the Philippines, or any other country where we or our service providers maintain facilities. We are committed to ensuring that any transfer of personal information is subjected to appropriate safeguards, regardless of the country or organization involved.

For data transfers from the European Union, we employ standard contractual clauses approved by the European Commission or employ other methods that are in compliance with European data protection laws to ensure adequate safeguards.

By utilizing our services, you consent and acknowledge that your information may be transferred to and processed in countries outside your country of residence. It’s important to note that these countries might have data protection laws that differ from those in your home country. Rest assured, we will implement necessary measures to make sure that your information is protected adequately in line with applicable laws.

11. Disclosure in Compliance with Legal Obligations

As a user of the Sites, you consent to our disclosure of your Personal Information in compliance with judicial and administrative processes, or to law enforcement or governmental agencies if legally bound to do so. Further, if we deem it necessary or appropriate in the context of an investigation into illicit or improper activities associated with the Sites, such as fraud, deceit, intellectual property violations, or any other actions that may place us under legal jeopardy, you authorize us to disclose your Personal Information.

12. Governing Law and Dispute Resolution

This Privacy Policy is governed by the laws of the State of Delaware and the United States of America, irrespective of conflict-of-law provisions. By using the Sites, you consent to the jurisdiction of these laws for any disputes that might arise between you and us or any of our affiliates concerning your use of the Sites.

In the event of a dispute, the aggrieved party must notify the other party in writing, detailing the nature of the dispute and the remedy sought. This can be done via email. We will communicate with you through the email address you provide, and you should direct your notices to us at privacy@igw.com with “DISPUTE NOTICE” in the subject line. The parties are obliged to attempt in good faith to resolve the issue amicably before escalating it to formal resolution means. If the dispute cannot be resolved through this process, mandatory arbitration as outlined in the Terms of Use may be pursued.

13. Severability

If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable, the validity, legality, and enforceability of the remaining provisions shall not be affected or impaired.

By using our services, you signify your understanding and acceptance of this Privacy Policy. If you do not agree with this policy, please refrain from using our services.