Privacy Policy

Last updated: June 1, 2023

This Privacy Policy explains how ALMA Games ("ALMA Games" or "we") collects, uses, and shares your personal information while you play ALMA Games's games ("Games") and/or use ALMA Games's websites that link to this Privacy Policy ("Websites").

In this notice, “Services” refers to our Games, Websites, and any related services or properties we control; “Games” refers to our games, applications, and other products; and “Websites” refers to websites and other online properties we control. The expression “your data” is used when referring to personal data that relates to you as an identified or identifiable individual.

We may make changes to this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we will notify you via email if we have your email address on record, or via a notice on the Websites and/or Games prior to the change becoming effective.

1 Contact information

In matters related to this notice, you can reach us by email at contact@alma-games.com.

2 Why do we process your data and on what basis?

We may use your data for various purposes in connection with our Services.

• When you use our Services, we process your data in ways that enable us to provide the Services to you (for example, saving your game progress).
• Your data also enables us to provide related services (for example, account services and support), to maintain our Services (for example, by troubleshooting issues you encounter or moderating our Games), and to improve the Services (for example, by running surveys to get your feedback).
• Moreover, we may show ads to you in our Games or advertise our Services to you on third-party properties, and may use your data to make this possible and to make those ads relevant to you.
• From time to time, we may need to use your data for other purposes such as fraud prevention, auditing, or compliance.

We do not use your data to make automated decisions which significantly affect you. By an “automated decision,” we mean a decision made by an information system without any human intervention.

2.1 Advertising

Advertising funds our Services and enables us to make our Games available free of charge. In our Games, we show our own ads and also ads from third parties. We also advertise outside of our Services on third-party properties such as websites or applications. In both scenarios, we and our advertising partners typically use pseudonymous identifiers related to your device to select ads which are relevant to you, to measure the effectiveness of advertising, and other related purposes. Where allowed by applicable laws and regulations, by using the Services you consent to us sharing your data to our advertising partners for interest-based advertising and other related purposes. You may manage your preferences in the settings of our Games or your device. 

In the list below, you will find information on the partners we work with while providing our Services who may collect or receive data relating to you from us or our Services and who process that data independently of us.

2.2 Cookies and similar technologies on our Websites

Like most websites today, our Websites may use cookies or similar technologies (for example, local shared objects or web beacons).

A “cookie” is a small file your browser stores when told to do so by a website. Cookies can be set by either the website you visit (“first-party cookies”) or a third party involved in providing content, functionality, or services such as analytics or advertising for the website you visit (“third-party cookies”). Cookies are typically used to identify or “remember” your device, for example to enable functionality, facilitate audience measurement, improve performance, or store your preferences.

When you visit our Websites, you may be prompted to make a choice regarding cookies. Some cookies may be strictly necessary for the operation of the Websites. These cookies will be used and stored on your device independent of your choices regarding other types of cookies. You can also control the use of cookies using your browser or device settings, for example by disabling some or all cookies or configuring your browser or device to notify you when cookies are being set. However, please consider that disabling cookies may affect your ability to use the Services.

3 What data do we process?

When you access and use our Services, we may collect information you submit to us or through the Services, for example when creating an account, sending messages in the Games, or contacting us for support. We may also automatically collect information about your use of the Services and the device you use to access the Services, including identifiers such as an Advertising ID. When you see our ads outside of our Services, we may collect information about your interactions with those ads. We may use the data we collect to infer other data, for example about your content preferences. 

We may process the following data relating to you:

• your name, email address, or other contact information if you have provided them to us (for example, when creating an account with us or subscribing to our communications),
• your age or information about when you were born,
• online identifiers such as your in-game alias, IP address, identifiers we assign to your account, or hardware or operating system based identifiers including your Advertising ID,
• technical information about the device you use to play our Games or use our other Services (for example, information about its type, model, manufacturer, operating system, language, display, processor, or memory),
• your coarse location (for example, country, state, or city), inferred from your IP address,
• information about your use of the Services (for example, information about your progress or purchases in our Games, your use of an account you have with us, your visits to our Websites, or your interactions with ads in our Games),
• information about your interactions with our ads outside of the Services (for example, on third-party websites or applications), including information on how you were referred to our Games or other Services,
• crash logs or other information related to bugs, errors, or other issues you encounter in our Services,
• inferences we make based on your activity in our Services (for example, about the content you might enjoy),
• messages or other communications you send to us or through the Services or related communities managed by us on third-party platforms (for example, your chat messages in our Games, emails you send to our support team, or messages you post to official community groups for the Games),
• if you choose to connect a third-party account (for example, a social media account) with our Services, information we receive from the third-party account provider (for example, an account name, identifier, or email address to enable cross-device gameplay or a profile name, picture, or friends information to provide social features),
• if you make purchases in our Games, information we receive from third-party payment service providers to validate those purchases (note that we do not receive your credit card or other payment method information when you make purchases in our Games),
• if you have subscribed to our communications, your content preferences or other information you submit to us when subscribing to our communications,
• if you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so (for example, information about your background or experience with our Games),
• information about your choices regarding your data (for example, any consents you may have given or withdrawn),
• any other information you choose to submit to us through our Services or otherwise, and
• with your consent, other information explained to you when asking for your consent (for example, your GPS location for location-based experiences).

We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.

4 Where do we collect your data from?

Primarily, we collect data directly from you or your device when you use our Services. However, we may also receive data about you from other companies, for example third-party login providers if you choose to use them, companies that facilitate the purchases you make in our Games, or advertising partners involved in delivering our ads to you outside of the Services. 

We may collect data relating to you from the following sources:

• directly from you when you submit it to us (for example, when registering an account with us, subscribing to our communications, sending support enquiries to us, or responding to our surveys),
• directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services (for example, on third-party websites or applications), including through cookies or similar technologies or software development kits (SDKs),
• companies that distribute or publish our Games,
• if you interact with ads in our Games or our ads outside of our Services (for example, on third-party websites or applications), from our advertising partners involved in the delivery and measurement of those ads,
• if you choose to connect a third-party account (for example, a social media account) with our Services, from the third-party account provider,
• if you participate in official community groups for our Games on third-party platforms, from those community groups or the platform provider,
• if you make purchases in our Services, from the third-party payment service provider involved in those transactions, or
• with your consent, from other sources explained to you when asking for your consent.

Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this notice, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games (or to utilize the privacy settings of those third-party services to control the extent to which your data is shared to us), to use options provided to you in our Games to manage your preferences regarding the use of your data for advertising purposes, to use your device settings to reset or control the use of your Advertising ID or to toggle features such as push notifications or location tracking, or disable some or all cookies from your browser settings. At the same time, please be aware that our Websites may not respond to “Do Not Track” signals in HTTP headers.

5 Who do we share your data with?

As we operate the Services globally, your data is likely to be transferred to and/or processed in countries other than your home country when you access or use our Services. Where allowed by applicable laws and regulations, you consent to the transfer of your data outside of your home country by using the Services. By design, some information (such as your in-game alias or chat messages) may also be visible to other users of our Services. More rarely, we may need to share data when making changes to our corporate structure, when required by applicable law or regulation, or when necessary for our legal rights or someone’s vital interests. 

6 How long do we keep your data?

We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. We may periodically delete or de-identify inactive accounts or other data in our Games or other Services.

After the applicable retention period, we will either delete or de-identify your data or, if neither deletion or de-identification is possible (for example, due to data being stored on a backup server), isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregate data).

7 How do we keep your data secure?

We have adopted measures to provide your data a level of security appropriate for the degree of risk involved with the processing activities described in this notice. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ vary, but typically include, for example, encryption in transit, pseudonymization of identifying data where feasible, controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents. Please consider that, despite our efforts to secure your data, the internet is an inherently insecure environment and we cannot guarantee absolute security for your data.

8 Your rights

You have a number of rights to your data under applicable laws and regulations. If we are processing your data, you may ask to use these rights. For example, you may ask to access your data, to request its deletion, or to withdraw consent where applicable. Please check the settings menus of our Games to find options to use these rights, or contact us at contact@alma-games.com. 

If we are processing your data, you have the right to:

• access, correct, or request the deletion of your data,
• request us to restrict our processing of your data,
• object to our processing of your data to the extent our processing is based on our legitimate interests or the legitimate interests of a third party, or
• where technically feasible, request a copy of the personal data you have provided to us in machine-readable format.

Where our processing of your data is based on your consent, you also have the right to withdraw your consent at any time. Where applicable, you may manage your advertising preferences in the game settings under “Terms & Privacy” or a similarly named option. Please be aware that we may continue processing your data despite your withdrawal of consent, if we have a lawful basis for doing so.

9 Note for California residents

If you are a California resident, please be aware that under the California Consumer Privacy Act of 2018, as amended (“CCPA”), you are entitled to receive specific information on how we process your data. You also have specific rights to your data, including the right to opt out of the sale of your personal information. 

10 Children

Our Services are generally intended for adults and designed primarily with adults in mind. When you access and use our Services, we may ask you to confirm your age to us or your age may otherwise become known to us. If we discover that you are a minor or do not meet an age threshold we apply, we may take steps to limit, suspend, or terminate your access to the Services where we believe that to be necessary due to applicable regulatory or platform requirements or to provide you with an appropriate experience. If your access to the Services is not suspended or terminated, we will limit the use of your personal data to what is necessary for the internal operation of our Services and other uses permitted by applicable laws, regulations, and platform policies. This may include removing access to certain parts or features of the Services.