APPLICATION PRIVACY POLICY

(Last Updated 3 June 2018)

Our Privacy Commitment

This Application Privacy Policy (“RISK Privacy Policy”) explains how SMG Studio Pty Ltd (ACN 164 622 566) of 407 / 22 Mountain St, Ultimo, NSW 2007, Australia (collectively, “SMG”, “we”, “our”, or “us”) collects, uses, and discloses your information. This RISK Privacy Policy applies to information that we collect when you use the RISK: GLOBAL DOMINATION game application (“RISK App”). This RISK Privacy Policy and the ESRB certification seal shown confirm that SMG is a valid licensee, and participating member, of the Entertainment Software Rating Board's Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, we have voluntarily undertaken this privacy initiative and have had the RISK App reviewed and certified by ESRB Privacy Certified to meet established online information collection, use, and disclosure practices. As a licensee of this privacy program, we are subject to audits of the RISK App and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

We ask that you take the time to read this RISK Privacy Policy carefully. By using this RISK App, you agree to our RISK Privacy Policy. If you do not agree with this Privacy Policy, please exit and stop using the RISK App.

Table of Contents

1. Changes to this Privacy Policy

2. What this Privacy Policy Covers

3. Information Collected, Used, and Disclosed

4. Children Under 13 – NOTE TO PARENTS

5. Third-Party-Disclosures

6. Safeguarding Your Personal Information

7. Your Privacy Rights

8. Contact Us


1. Changes to this Privacy Policy

We encourage you to review this RISK Privacy Policy whenever you access the RISK App to make sure that you understand our information collection, use and disclosure practices. We may change the provisions of this RISK Privacy Policy at any time and will indicate when changes have been made by revising the date at the top of this RISK Privacy Policy. Your use of the RISK App, or any portion thereof, following the posting of such changes shall constitute your consent to such changes. If we make material changes to this RISK Privacy Policy, we will provide you with additional notice of such changes by updating the description of the RISK App in the applicable app store. If you do not agree with the changes we make to this Privacy Policy, please stop using and uninstall the RISK App.

2. What this Privacy Policy Covers

This RISK Privacy Policy is effective as of the date first posted above and applies only to information collected by SMG through the RISK App.

This RISK Privacy Policy does not apply to any other information collected by SMG through any other means. For clarity, this RISK Privacy Policy does not apply to any of SMG’s websites, SMG’s other mobile applications, or any apps or websites maintained by other companies or organizations to which we may link. Your use of any third party app and/or website is subject to such third party’s applicable privacy policies and terms of use, and we encourage you to read the third parties’ privacy policies and terms of use before submitting personal or other information or using that app and/or website.

3. Information Collected, Used, and Disclosed

Personal Information

We collect your personal information to the extent reasonably necessary to fulfil your requests and our legitimate business objectives. With the exception of your device identifier (or “device ID”, i.e., the identifier assigned to your device by your mobile operating system),IP address, and email address (if you contact our support team), we do not collect personal information from our users through the RISK App. We collect your device ID and IP address, which we use to create a randomised identifier (i.e., a “scrambled ID”) that is used to assist us in gathering non-personal analytics and statistical data regarding use of the RISK App (e.g., number of sessions, length of time in app, number of unique users, etc.). This information is also used to send you push notifications, should you opt-in to receiving them. You may disable push notifications at any time through the settings within the RISK App or your device settings.

We may also collect and share your device ID,IP address and ad tags with third parties that we engage to help us advertise the RISK App. This information may also be combined with other information about your activities on the RISK App and the SMG and third party websites and applications where we serve ads about the RISK App. For more information about our advertising practices in connection with the RISK App, please reference “About Our Ads” in the section of this RISK Privacy Policy discussing Third-Party Disclosures below.

Please note that we collect your email address and any personal information provided by you to us via our customer support email when you make a support request. Additionally, if you connect your social media profile (e.g. Facebook) with the RISK App, we collect information about your friends list to allow you to play with your friends who may also use the RISK App or to invite them to play.We retain your personal information for as long as reasonably necessary to fulfil the purposes outlined in this RISK Privacy Policy and in accordance with our retention policies, as applicable, unless a longer retention period is required by applicable laws and/or regulations.

LEGAL BASIS FOR PROCESSING (EEA users only)

If you are a user from the European Economic Area (EEA), our legal basis for collecting and processing the information described above will depend on the information concerned and the specific context in which we collect and process it. We collect and process information from you only where we have your consent (Art. 6 para 1 lit. a) GDPR), where we need the information to provide our contractual obligation to you (Art. 6 para 1 lit. b) GDPR) or where we have a legitimate interest to do so. If you wish to learn more about specific legal ground(s) we rely on to process your information for any particular purpose (including any legitimate interests we have to process information), then please contact us using the details provided below under “Contact Us”. However, by way of example, we rely on our legitimate interests to process information for direct marketing purposes and for fraud prevention and detection, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms (Art. 6 para 1 lit. f) GDPR).

INTERNATIONAL TRANSFERS OF PERSONAL DATA

The data servers used for our app are located in countries outside your own country and outside the European Union, specifically in the United States of America and in Australia. The laws applicable to the protection of personal data in those countries may be different from those applicable in your home country. In particular, if you are using the app from within the European Union, please note that personal data collected within the app will be transferred outside the European Union. By using the app, you consent to personal data about you being transferred outside your own country and, where applicable, outside the European Union.

Non-personal Information

We may also collect non-personal information from you in connection with your use of the RISK App. For example, we may collect device type, country of access, and other game play information, which is used to assist us in gathering non-personal analytics and statistical data regarding use of the RISK App.

Also, the RISK App offers the ability to unlock unlimited play via an in-app purchase. If you make such a purchase, your credit card or other payment information will be collected and processed by the applicable third-party service provider (e.g. Google Play, Apple, Amazon, PayPal). The third party service provider will notify us that the purchase has been made so that we can make the purchased content available to you.

4. Children Under 13 - NOTE TO PARENTS

With the exception of a device ID and IP address necessary to operate the RISK App, we do not knowingly solicit or collect personal information from children under 13 in connection with the RISK App. We do not use a child’s device information to send push notifications, nor do we let them connect a social media profile to the RISK App. However, if you believe that we may have unintentionally collected your and/or your child’s personal information, you may contact us at:

SMG Studio Pty Ltd
Attn: Ashley Ringrose – Studio Head
407 / 22 Mountain Street
Ultimo
NSW 2007
Australia

ringrose@smgstudio.com

Please note that any personal information provided by you to us via any customer support website is subject to the privacy policy and terms of use of that website. Please read those documents before providing any personal information to us via any customer support website.

5. Third-Party Disclosures

We use third party service providers to assist us in gathering certain data, including game play information, device type, number of unique users, and country of access. We use this information, which does not identify individual users, to analyse trends and to gather demographic information about our user base as a whole.

We use two third-party service providers, to assist us in gathering analytics and statistical data in connection with the Apps. Those third-party service providers are:

- Google Analytics; and

- Facebook SDK.

If you have any questions or concerns with regards to Google Analytics or Facebook SDK’s privacy practices, you may review their privacy policy at:

- Google: https://www.google.com/intl/en/policies/privacy/

- Facebook SDK: https://www.facebook.com/about/privacy/

or contact them at:

Google Analytics
Google Inc.
1600 Amphitheatre Parkway
Mountain View
CA 94043
USA

https://support.google.com/policies/troubleshooter/2990837?hl=en

Facebook SDK
(If you live in the US or Canada)
Facebook, Inc.
1601 Willow Road
Menlo Park, CA 94025
USA

If you live anywhere else
Facebook Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2
Ireland

https://www.facebook.com/help/contact/1461223320847982

The RISK App offers the ability to unlock unlimited play via an in-app purchase. If making such a purchase, your credit card or other payment information will be collected and processed by the third-party service provider (e.g., Google Play, Apple, Amazon, PayPal). We will notify you when you are leaving the RISK App or otherwise indicate that you will be going to the third-party's site. Your use of the third party website is subject to their privacy policies and terms of use, and we encourage you to read such privacy policies and terms of use before submitting personal or other information or using the websites.

About Our Ads

We may engage third parties, such as Unity Ads, App Lovin, Supersonic and Facebook (“Ad Partners”), to: (i) serve ads for the RISK App on third party websites and applications; and (ii) track the performance of such ads. In order to perform such activities, these third parties may use software development kits and other technologies to collect information about those third party websites and applications where the ads are served, and your activities on the RISK App. This may occur, for example, when you click on or scroll over an ad. The information collected typically includes: device ID; IP address; click identifier, which tracks click activity on a particular ad; and information specific to the ad campaign (e.g., campaign name, etc.).

We do not use this information to deliver advertising and/or content targeted to your interests, though the third parties with whom we share this information may use it for that purpose. For more information about targeted advertising in connection with these third parties, and how to opt-out of having your information used in this way, please visit: http://youradchoices.com/appchoices or http://www.networkadvertising.org/mobile-choice. To opt out of these third parties’ use of your application activity for targeted advertising purposes, please use the settings available on your device (“Limit Ad Tracking” for iOS or “Opt Out of Interest-Based Ads” on Android).

More specifically, if you would like to opt-out of having your information used this way by the Ad Partners please opt-out through the Ad Partners directly. If you have any questions or concerns with regards to privacy practices of the Ad Partners, you may review their privacy policies at the following websites:

- Unity Ads: https://unity3d.com/legal/privacy-policy

- App Lovin: https://www.applovin.com/privacy

- Supersonic: https://www.supersonic.com/privacy-policy/

- Facebook: https://www.facebook.com/about/privacy/

Alternatively you may contact the Ad Partners at:

Unity Ads
Unity Technologies,
30 3rd Street,
San Francisco, CA 94103
USA

privacy@unity3d.com

App Lovin
AppLovin Corporation
849 High St.
Palo Alto, CA 94301
USA

care@AppLovin.com
legal@AppLovin.com

Supersonic
1450 2nd Street
Suite 227
Santa Monica, CA 90401
USA

legal@ironsrc.com

Facebook
(If you live in the US or Canada)
Facebook, Inc.
1601 Willow Road
Menlo Park, CA 94025
USA

If you live anywhere else
Facebook Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2
Ireland

https://www.facebook.com/help/contact/1461223320847982

Disclosures to Help Protect the Security and Safety of the App

We do not share your personal information with third parties other than as described in this RISK Privacy Policy, or in connection with the RISK App, including:

- with your consent, including if we notify you through the RISK App that the information you provide will be shared in a particular manner and you provide such information;

- with third party vendors, consultants and other service providers who are working on our behalf and need access to your information to carry out their work for us. These entities have agreed to maintain the confidentiality, security, and integrity of the personal information they obtain from us, and, unless we notify you otherwise and provide you with an opportunity to opt-out, will not use your personal information for any purpose other than as described in this RISK Privacy Policy.

- when we believe it is necessary or appropriate to (i) comply with applicable law or legal process or to respond to lawful requests or legal authorities; (ii) protect the rights and property of SMG and our employees, agents, users and other third parties, including to enforce our agreements, policies and the Terms and Conditions of Use for the App and protect against fraudulent, abusive, inappropriate, or unlawful use of the App or our products; and (iii) protect the safety of SMG, our users or any third party; and

- in connection with, or during negotiations of, any merger, sale of company assets, bankruptcy or reorganisation, financing or acquisition of all or a portion of our business to another company.

6. Safeguarding Your Personal Information

SMG has established policies in an effort to protect your personal information against loss, misuse and unauthorized access, disclosure, alteration and/or destruction. For example, SMG strives to provide only those employees performing a legitimate business function with access to users’ personal information. SMG also reviews its security procedures periodically to consider appropriate new technology and updated methods.

SMG retains your information for business purposes, for as long as your account is active (if applicable), and/or as long as is reasonably necessary to provide you with access to the RISK App and/or our other products and services. SMG will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time.

Despite our efforts, please be aware that no security measure is ever perfect or impenetrable. To that end, SMG will notify users of a data breach when SMG determines that is reasonably necessary in accordance with applicable law.

7. Your Privacy Rights

You have a right to request access to review and/or modify (including delete) your personal information, to withdraw consent (if applicable), or to object to our processing of your personal information. You may also contact us to request certain information regarding our disclosure to third parties for their direct marketing purposes. If you are the parent of one of our users, you also have a right to request more information.

If you wish to exercise any of the above rights, please contact us using the information within the next section of this RISK Privacy Policy.

Users who wish to limit ad tracking by third parties on their mobile device should follow the below instructions.

iOS – On your iOS device (iPhone or iPad), open “Settings > Privacy > Advertising” and turn on “Limit Ad Tracking”

Android – On your Android device, open “Settings > Ads” and turn on “Opt out of interest-based ads”

An IDFA can also be reset on the above settings pages.

8. Contact Us

If you have questions or concerns regarding this Privacy Policy, please contact us at:

SMG Studio Pty Ltd
Attn: Ashley Ringrose – Studio Head
407 / 22 Mountain Street
Ultimo
NSW 2007
Australia

ringrose@smgstudio.com