1. Introduction

This privacy policy is effective as of June 29th 2023.

North Sky Games Inc ("North Sky Games", "we", "us") has developed this Privacy Policy to help you understand how we collect, use and protect the information we may acquire through your use of any North Sky Games game or any website operated by North Sky Games (the "Services"). Your privacy is important to us and we encourage you to read this Privacy Policy carefully so that you can make informed decisions about your use of the Services. North Sky Games develops and publishes games for desktop and mobile device.

By installing, playing our games or otherwise accessing our services, you agree to the use of your information in accordance with this privacy policy. If you do not agree with this privacy policy, you should not be playing our games or accessing our services.

2. Collection of Information

We collect information from a variety of sources, but most of it comes from you when you play our games or interact with our services. The information includes the type of devices you are using, how you play our games as well as information you submit when creating an account with us by connecting to your social networking accounts through our games or Services. We may also collect information from our advertising platforms and partners and other third parties.

2.1 Mobile Analytics

North Sky Games uses analytics software to allow us to better understand how our games are used by our users. This software may record information such as how often you use our games, specific events that occur within the game, performance data, crash reports as well as aggregate usage. We do not link any of that data to any personal information that you submit within the mobile application. We use the data provided to create reports, analysis or similar services for use by us for the purpose or research or business intelligence. For example, we may use analytics to track specific trends within our games or to test out new features and content.

2.2 Social Networks

When playing our games, you will be offered the option of connecting with social networks such as Facebook. North Sky Games will then receive information about you from the third-party and use that information to create an account with PlayFab for the game. The account will be linked with the social networking account and will include some personal information such as your first and last name, user ID number (like your Facebook ID number), login email, physical location, friends list as well as any additional information that you or the provider shares with us.

The account created with PlayFab will then periodically save your personal progress within our games. This can include statistics, currencies earned or purchased, unlocked content, level achieved, leaderboards and tournament rewards and any additional information the game needs to fully restore your progress. Connecting a new device to your account will then load your progress unto that device, ensuring that your progress is never lost.

2.3 Ad Networks

North Sky Games may feature advertising within our games and Services. We use a variety of advertising partners, including ad exchanges, ad networks and ad servers. Our advertising partners help us serve advertisements to you within our games. Our advertising partners may collect information about you when you play our games or the services of others. This privacy policy does not apply to the collection of your information by our advertising partners.

Advertisers on mobile devices use your device’s advertising identifier to optimize their advertising. 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 on your device. Settings will vary for each device but will usually be found under privacy or ads in your device’s settings.

2.4 Customer Service

We use the information you provide us directly in communications to provide you with support through our customer service system. The information provided may include information about platform and device type you are using, account information is connected with our service, name and email address. We will use the information provided to provide you with the help you need and will only retain the communications as long as needed or required by law.

2.5 IAB Europe Transparency & Consent Framework

North Sky Games participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. North Sky Games uses the Consent Management Platform with the identification number 291.

3. How we Use the Information we Collect

The main use of the information we collect is improve our games and provide a better gaming experience. The uses for which we collect information include:

- To operate, improve and optimize our games as well as our player’s experiences. - To create an account with PlayFab and save your games’ progress.
- To enable players to compete with each other for prizes and to administer rewards for those events.
- To provide technical support and responds to players inquiries.
- To manage and deliver contextual and behavioral advertising.
- To notify players of in-game updates, new products and promotional offers.
- To conduct market and behavioral research.
- If you purchase goods or services, third-party applications such as the Apple App Store and Google Play Store will process the payment information on behalf of North Sky Games. We do not get access or retain any of your personal information from such transactions.
- If you submit a customer support request, we will use that information to respond to your request and help you resolve the issue or question you have regarding our games.

4. How we Share your Information

We may disclose or publish aggregated information and other non-personal information about our players for business purposes. In addition, we may share information with third parties or allow third parties to collect this information from our games in the following circumstances:

- With your consent, we may share your information with third parties or allow them to collect information from our games in some ways not specifically described in this privacy policy.
- Where your data is on an anonymous or aggregated basis such that you could not be personally identified by it.
- North Sky Games works with third party vendors to provide you with services within the games. Such third-party vendors include Analytics providers, customer support and account services (PlayFab) used to store and manage your account information. While providing these services to North Sky Games, these providers may have access to your personal information.
- When you submit information as part of a competition or participate in an in-game event or tournament, we may publish the information you submitted alongside your name on our website and social media channels.
- If North Sky Games becomes involved in a merger, acquisition or other transaction involving the sale of some or all of North Sky Games’ assets, user information, including personal information collected could be included as part of the sale. Should such an event occur, North Sky Games will use reasonable means to notify you through a prominent notice on our Services.
- We disclose information to respond to subpoenas, court orders and other legal processes as well as to establish/exercise our legal rights or defend against legal claims. We will share Personal Information and Non-Personal Information in order to investigate, prevent or take action against illegal activities, suspected fraud, potential threats to the physical safety of any person, violations of our Terms of Use or as otherwise required by law.

5. Accessing and Managing your Information

To manage the information North Sky Games receives from third-party services and applications, like Facebook, you will need to follow their instructions to update your information and change your privacy settings. You can also manage some aspects of the information collected by visiting the settings on your mobile device and reviewing the permissions for each app.

You have a right to know what information we have about you and in some cases to have that information communicated to you. If you wish to exercise that right, please contact us from within any of our game and let us know what information you wish to receive. We will provide you with an answer within 30 days of receipt of the request.

In some circumstance, you might wish to have some or all of the information we hold about you deleted. If you wish to do so, please contact us with your request. Please note that to ensure that no further information is collected, you might need to disconnect the game from social networks and in some cases, remove the game from your device. While we will make every effort to delete the information we have about you, we may need to retain some of that information for other purposes, such as maintaining financial records or for legal purposes.

There are other ways by which you can control the information we collect about you. You can disconnect the game from social networks or delete our games from your devices. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings on your phone. Note that you will still receive advertising but they will not be based on your activity across unrelated apps.

6. Data Retention

We will keep your information for as long as is necessary for the purposes described above, or as long as the law allows. We use third party services to store your data, including PlayFab and Amazon Web Services to process and store your information for us.

Even if information is changed or deleted, we may still retain some of the information to resolve disputes, enforce our user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

You can email us at support@northskygames.com to request data deletion. Also, you can choose to delete your account when logged into our games. On the profile page, select the delete account button and follow those steps to delete your account information.

7. Data Rights

7.1. Your Rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

If you are a resident of California, you have the following rights:
- Right to Know and Access Information: You have the right to request that we disclose what personal information we collect, use, disclose, and sell. To make such a request, please contact us.
- Right to Delete: You have the right to request the deletion of your personal information. To make such a request, please contact us.
- Right to Opt-Out of Sale of Personal Information: If we sell personal information, you have the right to opt-out. If we do not sell personal information, we will state this clearly. If applicable, a link titled "Do Not Sell My Personal Information" will be provided on our website.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA or CPRA rights.
- Minors Under 16 Years of Age: If we have actual knowledge that we collect or maintain the personal information of minors under 16 years of age, we will provide specific protections.
For more information on how to exercise these rights, please contact us

7.2. Your Rights under the Colorado Privacy Act (CPA)

If you are a resident of Colorado, you have the following rights under the CPA:
- Right to Access, Correct, or Delete: You have the right to access your personal data, to request that we correct inaccurate personal data, and to delete your personal data under certain circumstances. To exercise these rights, please contact us.
- Right to Data Portability: You have the right to receive your personal data in a portable and readily usable format.
- Right to Opt-Out: You have the right to opt-out of the processing of your personal data for targeted advertising purposes, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CPA rights.
For more information on how to exercise these rights, please contact us

7.3. Your Rights Under the Virginia Consumer Data Protection Act (VCDPA)

If you are a resident of Virginia, you have the following rights:
- The right to access the personal data we have collected about you during the past 12 months, including the categories of personal data; the categories of sources; the business or commercial purpose; the categories of third parties with whom we share personal data, and specific pieces of personal data we have collected about you. To exercise these rights, please contact us.
- The right to delete personal data we have collected from you, subject to certain exceptions in the VCDPA.
- The right to opt out of our sale or sharing of your personal data.
- The right to not be discriminated against for exercising any of your rights under the VCDPA.
To exercise any of these rights, please contact us using the contact details provided in this policy. We may ask you to verify your identity before responding to your requests.

7.4. Your Rights Under the Connecticut Data Privacy Act (CTDPA)

If you are a resident of Connecticut:
- You have the right to request the specific pieces of personal data we have collected about you in the past 12 months, including the categories of personal data, the sources from which the personal data was collected, the purposes for collecting or selling the personal data, and the third parties with whom we share personal data.
- You have the right to request deletion of your personal data.
- You have the right to opt out of the sale or sharing of your personal data.
- You will not be discriminated against for exercising your privacy rights under the CTDPA.
To exercise any of these rights, please contact us using the contact details provided in this policy. We may ask you to verify your identity before responding to your requests.

7.5. Your Rights Under the Utah Consumer Privacy Act (UCPA)

If you are a resident of Utah:
- You have the right to request access to the personal data we have collected about you in the past 12 months, including the categories of personal data, the sources of personal data, the business or commercial purposes for collecting the personal data, the categories of third parties with whom we share personal data, and specific pieces of personal data we have collected about you.
- You have the right to request deletion of your personal data.
- You have the right to opt out of the sale or sharing of your personal data.
- You will not be discriminated against for exercising your privacy rights under the UCPA.
To exercise any of these rights, please contact us using the contact details provided in this policy. We may ask you to verify your identity before responding to your requests.

8. Third Party Terms and Conditions

Please note that your access to and use of the Services may be subject to certain third-party terms and conditions and privacy policies, including but not limited to application stores, on-line gaming platforms and social networking services. You recognize and agree that North Sky Games is not liable for any such third-party terms and conditions and any third party's use of your Personal Information.

We do not collect, store or share your financial information. However, if you bought or otherwise accessed the Services through a third-party distributor such as Apple, Google or Amazon, that company may collect and store your Financial Information. Please review any applicable Distributor's privacy policies to see how it handles your information. Here are links to the privacy policies of a few of the Distributors we use:

Apple - http://www.apple.com/privacy/
Google - https://policies.google.com/privacy?hl=en&gl=us
Microsoft - http://privacy.microsoft.com/en-us/default.mspx

We may offer links to advertisements and/or enable you to access third-party products or services. While using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by us. We are not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them or any products or services they may offer. Links to products or services do not constitute sponsorship of, or affiliation with, those people or companies.

9. Our Policy Concerning Children

Our games and Services are not directed to children under 13. North Sky Games does not knowingly collect personally identifiable information from children under the age of 18. If it comes to our attention that Personal Information has been collected from a person under the age of 18, we will delete this information as quickly as possible. If you believe that we may have Personal Information from or about a child under the age of 18, please contact us at the email address below.

10. Changes to the Policy

This privacy policy may change over time. We will post the updated privacy policy on this page. Please come back to this back every now and then to make sure you are familiar with the latest version.

11. Contact Us

If you have any concerns about our use of information or compliance with these terms please contact us in writing at support@northskygames.com. We are committed to resolving any concerns or complaints regarding the collection, use, transfer or disclosure of information in an amicable and collaborative way.