Privacy Policy

Last Updated: 01-24-2023

Overview

5x5 Gaming, Inc. and its affiliates (collectively “5x5”, “we”, “us”, or “our”) respect your privacy and are committed to protecting it through our compliance with this policy (“Privacy Policy”). Our Privacy Policy describes the types of information we collect from you or that you provide to us, and our practices for using, maintaining, and disclosing that information. Capitalized words or phrases not defined herein shall have the meaning assigned to them in our Terms of Service.

This Privacy Policy applies to information we collect:

  • In our Games, whether on our Sites, www.5x5gaming.com or www.battleofkingdoms.com,  or other websites and forums operated by us
  • Through mobile applications you use to access our Services.
  • When you interact with our advertising and Services on third-party websites and platforms.

In the event our Site contains links to third-party sites and services, please be aware that those sites have their own privacy policies. After following a link to any third-party content, you should read their privacy policy before you share any personal information with them. This Privacy Policy does not apply to any third-party sites or your activity after you leave our Site.

Please read this carefully. By downloading, accessing and/or playing our Games, or interacting with our Sites or other Services, you affirm that you have read and understand this Privacy Policy and that you consent to the collection and use of your personal information as outlined herein. 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.

How We Collect Information

We collect information in a variety of ways, including but not limited to:

  • Directly: We collect information which you directly provide to us, including when you create an account with us or choose to provide additional information for your 5x5 Gaming Profile, interact with our customer service or request our assistance via email, our online chat, when you subscribe to our services, if you purchase Virtual Money or Virtual Goods[, other?].
  • Indirectly: We may collect information which you indirectly provide to us while interacting with us such as when you use any of our Services or communicate with us.
  • From Third Parties: We collect information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the Cookies, Ad Identifiers and Similar Technologies section below for more detail on the use of cookies.
  • From Publicly Available Sources: We may also collect information from publicly available sources, such as information from social media accounts and profiles, where relevant to your interactions with us, or to our business or relationship with you.

We need to collect personal information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Information We Collect

Depending on which Services you interact with, we may collect and process the following types of information about you:

Information Provided by You. This may include:

  • Your name, email address, date of birth, mailing address, and phone number.
  • Your social media profiles.
  • Your crypto wallet address, including related data used to detect cryptocurrency and NFT holdings.
  • Your payment details (through our third-party payment processor, but this information is temporarily cached in a way that is unreadable by 5x5 as we do not retain credit card information).
  • Additional information you provide us when you submit forms, answer questions or complete surveys through your use of our Services, associated social media platforms and/or accounts from which you permit us to collect information.
  • The content of messages sent using our chat and messaging systems.
  • If you contact us, for instance through our 5x5 Gaming Community customer service channels or respond to messages and communications that we send to you, we may keep a record of that correspondence.

Information Created During Your Use of the Services. This may include:

  • Details about how you use and interact with our Services (such as how and when you play our Games or visit our Sites, what device you use to access our games and services or details regarding profile visits).
  • Your interactions with us on our social media channels.
  • Your connections with others whose information we may collect.
  • Information about your access and use of our Services, including through the use of cookies, your communications with the Services, the type of browser you are using, the type of operating system you are using and the domain name of your internet service provider.
  • Your game progression data, such as game saves and your achievements.
  • Device information, such as mobile device type, device specifications, or other information from your device, for example, if you allow us to access your contacts to enable you to invite your friends to play our Games.

If you choose not to create a 5x5 Gaming Profile by connecting your social media account (as discussed below in 5x5 Gaming Profile and Playing Socially) the information that we collect when you play will be anonymous, but 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 Services, such as IP address, device identifiers, ad identifiers, a 5x5-specific player ID, and the country or region you are playing in.
  • How you play our Games and interact with our Services (such as which games you are playing, Game progress, session time and duration, number of attempts at each level and purchases).

Information From Other Sources. This may include:

  • Information we collect about you from our affiliates or other third-party companies who have obtained your consent or have another legal right to share such information with us (including publishing partners, platforms, payment processors, advertising platforms and partners, and data aggregators).
  • Publicly available information from your social media accounts, posts, and profiles, where relevant to your interactions with us, or to our business or relationship to you.

How We Use Your Information

Providing and Optimizing Our Services. We use your information to enable us to provide our Games, Sites, and other Services to you and to optimize them so that we can make them the best they can be for you and all our players. We may use the information that we collect on an anonymized or aggregated basis for product development, to analyse the performance of our games, to troubleshoot and to improve and optimize the games to ensure the best player experience for our players as a whole. This helps us to make sure our Services work properly on all devices and are enjoyable for all our players.

Customer Services. We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels, such as the 5x5 Gaming Community at www.5x5gaming.com/index.html, when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.

Non-Marketing Communications. We may use the information we collect to inform you of changes to our Terms of Service, Services, or policies; or we may send other communications that are not for the purposes of marketing our Services or products of 5x5 or our partners.

Analytics, Research and Development. We use analytics tools, which may include third party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar 5x5 technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may 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. We may aggregate and/or anonymize information so that will no longer be considered personal information. We do this to generate other data for our use, which we may use and disclose for any purpose, as it is no longer personally identifiable to you or any other user.

Social and Community. We have a number of 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, and we may republish your posts to those channels. Additional information regarding our practices as they relate to social gaming and the information we receive and share with third-party platforms in the 5x5 Gaming Profile and Playing Socially section below.

Chat. Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players, to 5x5 customer services or publicly on our forums. Your messages may 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 review the content of your messages, including by using automatic filters, to ensure that you are complying with our Terms of Service and 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.

Video Chat. Some of our games may also include a video chat feature. Users of this feature may be able to participate in video chat with contacts from a platform or social network or invite personal contacts. We will collect usage information from video chat interactions with other users, for example call duration, and general location information. We do not record, collect or retain any content of your video chat interactions with other users. Nor do we collect or store your date of birth information which you provide to us when activating the video chat feature for the first time, which is solely used to determine if you are eligible to use the feature.

Promotions and Competitions. From time to time, we may run promotions or competitions during which we may collect certain personal information from you or other information or content you submitted 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 may also publish the names and entries of competition entrants. That information may also be combined with your 5x5 Gaming Profile and other account information and will be processed, stored and shared in accordance with this Privacy Policy.

Marketing and Advertising. We may use the information we collect to market our Services to you. This includes sending you communications about our Games, Services, features, promotions, competitions, surveys, news, updates and events. We may use your information to personalize the marketing communications (including advertisements) that we send, including based on your location, past use of our Games and Services, and your preferences and settings. Please review the Marketing and Advertising section below for additional information.

Cheating, Crime and Fraud Prevention. We may use personal information that we hold to investigate, review and prevent cheating, crime, or fraud. When necessary, we may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention, such as the police.

Legal Uses. We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this could include for the purpose of providing VAT invoices where we are required to do so by law or when requested by you. We may also use your information to investigate, review, mitigate risks associated with, and inform you or appropriate authorities of, any data or security breaches involving your personal data. Your information may be used by us to ensure compliance with our Terms of Service, or where necessary to defend, exercise or establish our legal rights including our rights under our Terms of Service.

Other Purposes. We may use your information for other purposes upon notice to you, and your consent, at the time of collection, or in accordance with any other agreement you enter into with us. 

DATA SHARING AND Disclosing Information

Other Purposes. We may use your information for other purposes upon notice to you, and your consent, at the time of collection, or in accordance with any other agreement you enter into with us. 

Some of 5x5’s Games, Services and features require that we share information with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes for the purposes described in this Privacy Policy. We may disclose information to:

  • A parent, subsidiary, or affiliate of 5x5.
  • Third-party service providers for the purpose of enabling them to provide their services, including, without limitation, IT service providers, data storage, hosting and server providers, analytics, error loggers, marketing or advertising providers, maintenance or problem-solving providers, professional advisors, and payment systems operators.
  • Our employees, contractors, sub-contractors, and/or related entities who assist us in providing information, products, services or direct marketing to you.
  • Our existing or potential agents or business partners.
  • Third parties who collect and process data.
  • Third-party platforms on which you access or link to our Games or Services.
  • An entity that buys, or to which we transfer all or substantially all of our assets and business.
  • To any other parties as requested or consented to by you.

Some external business partners may also collect information directly from you, such as billing and payment information, in accordance with their own privacy policies. These external service providers do not share your financial information with us but may share limited information with us related to your purchase.

We reserve the right to disclose your information if we are required to do so by law. We may also disclose your information to law enforcement or in civil litigation in connection with the enforcement of our rights or your legal obligations.

While using the Services, you may choose to disclose personal information. You may elect to disclose information while playing the Game, on message boards, chat, video chat, on your 5x5 Gaming Profile, or any other features to which you are able to post your content. Please be aware that when you post to our forums, such as 5x5 Gaming Community, anything you contribute will be public and can be read and/or used by others. Only share content that you are comfortable sharing publicly.

5x5 Gaming Profile and Playing Socially

You can choose to add information to your 5x5 Gaming Profile or to connect our Services to your account with a third-party network (such as Facebook). If you do so, 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.

5x5 Gaming Profile. When you play our games, we will give you a randomly generated unique identifier which we will associate with a 5x5 Gaming account known as a "5x5 Gaming Profile". Your 5x5 Gaming Profile will not be personally identifiable unless you choose to add your personal information to it, such as your name, avatar, email address or other information. Your 5x5 Gaming Profile and the information it contains will be visible to other users of our Services. If you choose to add personal information to your 5x5 Gaming Profile it will be visible to your friends and other players anywhere in the world. If you choose to view another individual's 5x5 Gaming 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 5x5 Gaming Profile will be displayed on that individual's 5x5 Gaming Profile.

Connecting With a Third-Party OAuth Service. Where we make this available, you can choose to log in to your 5x5 Gaming Profile using your account details with a third-party service, such as Facebook or Google. 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, ask 5x5 Gaming other players for lives and messaging.

Information We Receive From Facebook. If you log in to your 5x5 Gaming Profile using your Facebook account details, we will receive some of your Facebook account information. If you choose to play our games on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your 5x5 Gaming Profile. The information we receive will depend on your Facebook account settings, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information. We will also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our Games. You can choose not to allow us to access your email address in the Facebook dialog box the first time at which you associate your Facebook account with your 5x5 Gaming Profile. Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see you and your progression in our games, you can prevent this by disconnecting your Facebook account from within our Games and updating your app permissions from within your Facebook settings. We recommend you read Facebook’s Privacy Policy (https://www.facebook.com/full_data_use_policy) and review your privacy settings from time to time to make sure that you understand fully how your Facebook data is shared.

Information We Receive From Google. If you log in to your 5x5 Gaming Profile using your Google account details, we will receive some of your Google account information. The information we receive will depend on your Google account settings, but typically we will receive your basic public profile information and profile picture. If you choose to grant us access to your contact list, we will use and store this to help you find those of your Google contacts that are already playing our games. You can revoke future access to your Google account at any time by following the steps at https://support.google.com/accounts/answer/112802?hl=en. We would recommend that you read Google’s Privacy Policy (https://www.google.com/policies/privacy/) and review your privacy settings from time to time to make sure that you understand fully how your Google data is shared.

Cookies, Ad Identifiers, and Similar Technologies

5x5 and our partners use cookies, ad identifiers and similar technologies on our Games, apps, Sites, emails, and online ads for purposes described in this Privacy Policy to enhance our Services and to collect data from your device. These technologies allow us and our third-party advertising partners to:

  • Recognize you and your device.
  • Provide interest-based advertising to you.
  • Allow our Services to interact with third-party social networks or platforms (where you have chosen to allow such interaction).
  • Allow us to understand how you interact with our Sites (such as Google Analytics).
  • Allow our payment processors to process your payment instructions.
  • Enable us and third parties to provide you with more customized services, such as to translate our Services to the correct language.

We may also allow our providers to conduct measurement and analytics services for us, to distribute online advertisements on our behalf and to track and report on their performance. These entities may use cookies, web beacons, and other similar technologies to identify the devices used by visitors to our Sites, as well as when they visit other online websites and services.

[Personalized Advertising. We may also use targeted advertising cookies, such as Google Ads, to deliver customized advertising on our Sites. You can learn more about how to control advertising cookies below in the How to Adjust Your Preferences for Interest-Based Advertising section. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.]

You may wish to restrict the use of cookies. Please be aware that some of the features on our Sites may not function correctly if you disable cookies. 

How Do These Technologies Work?

Ad identifiers are non-permanent, non-personal identifiers such as the Google Advertising ID (the “GAID”) and/or Apple's ID for advertising (the “IDFA”), which are uniquely associated with your device. Similar technologies include tracking 5x5 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.

Marketing and Advertising

Marketing. Unless you opt out as explained below, we and our third-party marketing partners use information collected about you to send you marketing communications about other 5x5 products, Games and related Services based on your interests. For example, we may send emails, serve ads within our Services or place ads on third party websites, apps and internet-connected devices. Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. By accepting this Privacy Policy and downloading or continuing to use our Services, and unless you opt out of interest-based advertising as explained below, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems. 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. A list of our marketing partners and their privacy policies can be found here.

Advertising. Our games may include advertising for third-party products and services. 5x5 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. [5x5 participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. 5x5 Gaming 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 may opt you into interest-based advertising by default. You can change your preferences at any time in the setting pages of our games. We use information that we hold about you to better target ads for third-party goods and services you might be most interested in. These ads may be shown to you within our games or Services. Our advertising partners may 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 your data 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. For more information, see How to Adjust Your Preferences for Interest-Based Advertising.

What information do we use for Advertising and marketing?

We use information about you to try to make sure you only see marketing from us that might be of interest to you, and that the ads you see in our Games are for products in which you may be interested. This includes using information that we may have about you, such as:

  • Ad identifiers and other non-personal information collected from your device. For more information, see Cookies, Ad Identifiers, and Similar Technologies.
  • The Games you play and information about how you interact with our Games and Services.
  • Your age, country or region, and gender.
  • Other 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.

Opt Out of direct marketing from 5x5

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

You should note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and you may see advertising for 5x5 products, but that advertising will not be targeted using your personal information.

How To Adjust Your Preferences for Interest-Based Advertising

You can choose to prevent your device's ad identifier being used for interest-based advertising by updating the settings on your device. If you opt out, you will still be able to play our Games and you may still see advertising in our Games, but those ads will not be targeted using information that we hold about you or which our advertising partners collect about you from our Games (subject to the exclusion below for players not in California). However, you may still receive ads based on contextual criteria such as the Game that the ad is displayed in, or the region in which your device is located.

For Players in California. The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) gives residents of the US state of California the right to prevent businesses from selling their personal information to third parties. Please see the Advertising Partners section for more information on how we work with our advertising partners. Sharing information in this way may be considered “selling” for the purposes of the CCPA. We do not “sell” your personal information to third parties for any other purpose. If you would prefer that your personal information is not shared with third parties for this purpose, you can update your preferences in relevant games via the settings menu. If you wish to opt-out of this ‘selling’ of personal information in all our games, you can submit a “Do not sell my personal information” request here.

For Players Not in California. If you would prefer that your personal data is not processed to receive interest-based ads, you can update your preferences via the settings menu in relevant games. You can also submit an opt-out request for all of our games here. Please note that outside of California, even if you have opted-out of interest-based ads in our games, you may still receive interest-based ads from Facebook. If you would prefer that Facebook does not use your personal data for interest-based ads, you need to log into your account on Facebook and update your settings there.

Opting Out of Interest-Based Advertising at a Device Level. You can choose to prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device. Settings vary from device to device, but you will usually find the ad identifier settings under "privacy" 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 participating in the Digital Advertising Alliance by visiting www.aboutads.info/choices (for US users), www.youronlinechoices.com (for EEA users) or youradchoices.ca/choices (for Canadian users). If available, you can also click on the AdChoices logo within an advertisement.

Your Rights and Controlling Your Personal Information

Your Choice. Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and/or your use of our Services.

Information from Third Parties. If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about someone else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Right of Access. You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right, please Contact Us and let us know what information you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes information about another person. If we are not able to provide you with information requested, we will tell you why.

Right to Correct. We try to keep the information that we hold about you accurate and up to date. Should you notice that any of your information is incorrect, please let us know at support@5x5gaming.com and we will correct it as soon as we can.

Data Deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us. Please note that 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. When we delete personal information about you, we may 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 such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, high scores, and any chat messages may be cached on other players’ devices which we may not be able to remove from those devices, for example if that device is not connected to a wi-fi network.

Account Deactivation. If you have created an account with us and wish to deactivate that account, please Contact Us. Additional information may be required before we can deactivate your account, such as information about your mobile device. If you wish to completely deactivate your account, you will also need to disassociate your Facebook account from our mobile Games and delete 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 Goods or Virtual Money will be lost, and we may not be able to restore them in the future.

Data Portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.

Restriction of Processing. In some cases, you may have the right to request a restriction of the processing of your personal data, 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 data about you which is processed on the grounds of legitimate interests (see Additional Disclosures for EEA and the U.K Residents).

Non-Discrimination. We will not discriminate against you for exercising any of your rights over your information.

Notification of Data Breaches. We will comply with laws applicable to us in respect of any data breach.

Complaints. If you believe we have breached data protection laws and wish to make a complaint, please Contact Us and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you advising of the outcome of our investigation and the steps we will take to address your complaint.

Unsubscribe: To unsubscribe from our emails or opt-out of communications, please Contact Us or use the opt-out or unsubscribe features in the communications.

Direct Marketing Opt Out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.

Additional Disclosures for California Residents

The CCPA affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. In the preceding 12 months, we have collected the following categories of personal information: identifiers, commercial information, internet or other electronic network activity information, and inferences. For details about the precise data points we collect and the categories of sources of such collection, please see the Information We Collect section above. We collect personal information for the business and commercial purposes described in the  How We Use Your Information  section  above.  In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Direct Marketing Opt Out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.

Category of Personal Information

Categories of Recipients

Ad Identifiers

Analytics Providers; Communication Providers; Customer Service Providers; Fraud Prevention and Security Providers; Infrastructure Providers; Marketing Providers; Payment Processors

Commercial Information

Analytics Providers; Infrastructure Providers; Payment Processors

Internet or Other Electronic Network Activity Information

Analytics Providers; Infrastructure Providers

Inferences

Analytics Providers; Infrastructure Providers

In addition to the rights listed in the Your Rights and Controlling Your Personal Information and How to Adjust Your Preferences for Interest-Based Advertising sections above, California residents have the following rights:

Third Party Marketing. California law further permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes.

Right to Opt-Out: In the preceding twelve months we have not sold personal information for monetary consideration, but we recognize that some state privacy laws define “personal information” in such a way that some sharing of personal information necessary to provide you with personalized ads may be considered a “sale”, even if no money is exchanged. California residents have the right to opt out of the sale of personal information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. If you opt-out, we will not share your information with our advertising partners, but you may still see ads in the game and some of our partners may deliver ads to you, based on information they hold on you. See How to Adjust Your Preferences for Interest-Based Advertising for more information. For the reporting information required by California Code Regulations Title 11 § 999.317, please click here.

Authorized Agents. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. This may include requiring you to verify your identity. If you are an authorized agent seeking to make a request, please Contact Us.

Additional Disclosures for EEA and the U.K. Residents

Residents in the European Economic Area and the United Kingdom (together, for the purposes of this Privacy Policy, “EEA”), as well as certain other jurisdictions, are entitled to certain rights and disclosures with respect to their personal information.

The legal bases which we rely upon for collecting and using your personal information include:

Contractual Necessity. This covers information used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our Games, customer services, chat functionality and third-party social network connectivity.

Legal Obligation. This covers information used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data.

Legitimate Interests. This covers information used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as marketing, advertising, analytics, research and optimisation of our Games and other Services.

Consent. This is used as a legal basis in the following contexts: (i) the collection of data stored on your device by us and our advertising partners, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our Game and you can withdraw your consent to this by uninstalling our Games; (ii) the storage of data on your device by us and our advertising partners, including through the use of cookies. By accessing and using our Services, you consent to this storage and you can withdraw your consent by updating your cookie settings; and (iii) the use of your data by us and our partners for targeted advertising purposes (for more information, see Marketing and Advertising). You consent to this collection when you accept this Privacy Policy, and you can withdraw your consent to this processing by following the steps in How to Adjust Your Preferences for Interest-Based Advertising. Where we ask for your consent to use your data for any other purpose, we will make this clear at the point of collection.

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 data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease playing our Games and stop using our Services.

Security

5x5 takes appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. Our security measures include standard data protection measures, as well as those described in the EU GDPR implementing regulations. In addition, we request that our suppliers 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. 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. Although we will do our best to protect the information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, nor can absolute data security be guaranteed. As such, you should always take care when sharing your personal information online.

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.

Information on Blockchain or Cryptocurrency Platforms. Please note that if you choose to make purchases of Virtual Money or Virtual Goods, the cryptocurrency platform, blockchain platform, and/or online wallet will indefinitely retain a publicly available transaction identifier in connection with your purchase. These platforms have their own privacy policies governing the retention of personal data, and we encourage you to refer to the specific platform’s privacy policy in connection with your purchase.

Location of storage; Transfer

We typically store your information on servers that we control which are primarily based in the EEA. However, we may also use servers and engage providers that are located outside the EEA to process and store your information and to provide services to us.

Your information, including personal information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. We may transfer your information to affiliated entities or third parties to jurisdictions outside the EEA. 5x5 will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your information will take place to an organization or country unless there are adequate controls in place, including the security of your data and other personal information.

South Korea

Please note that a different version of this Privacy Policy applies if you live in South Korea (please see https://www.5x5gaming.com/index.html).

Children’s Privacy

You must be over a certain age to play our Games and use our Services, depending on where you live. 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 knowingly allow such persons to use our Services. The table below sets out the minimum age you must be to play our Games and use our Services depending on the country where you reside. Our games are not intended to be played by children under the age of 13, regardless of where they live. We do not knowingly collect, and do not wish to collect, information about children. Please do not play our Games or use our Services if you are under the relevant age. If you believe that we have information from or about a child under the age set out below, please Contact Us.

Country

Minimum
Age

Country

Minimum Age

Country

Minimum Age

Country

Minimum Age

Austria

14

France

15

Malta

13

Sweden

13

Belgium

13

Germany

16

Netherlands

16

Switzerland

16

Bulgaria

16

Greece

16

Norway

13

United Kingdom

13

Croatia

16

Hungary

16

Poland

16

Everywhere else (excluding South Korea)

13

Republic of Cyprus

14

Ireland

16

Portugal

16

Czech Republic

16

Italy

14

Romania

16

Denmark

13

Latvia

13

Slovakia

16

Estonia

16

Lithuania

14

Slovenia

16

Finland

13

Luxembourg

16

Spain

14

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

Changes to this Privacy Policy

We may 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.

Data Controller

5x5 Gaming Inc. is the data controller for the personal information collected in connection with 5x5’s Games and Services. Our Data Protection Officer can be contacted at dataprotectionofficer@5x5gaming.com.

Contact us

If you have any questions or concerns regarding this Privacy Policy, or wish to exercise any of your rights contained herein please contact us: