Privacy Policy

Introduction

Privacy Policy (“Policy”) describes the way we collect and use your Information (as defined below) and informs you of your choices in relation to your Information. In this Policy, “Inrealms”, “we” or “us” refers to Inrealms LLC, a company registered in the United States; our Illinois business ID number is 09591915. We are the data controller under the applicable privacy laws. For the purpose of this Privacy Policy, “Information” means any information relating to an identified or identifiable individual. When you use our mobile games, you accept our rules and policies which describe how we handle your Information, and you understand we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not play our Games. If you change your mind in the future, you must stop playing our Games and you may exercise your rights in relation to your Information as set out in this Policy.

The Information we collect

Information you may provide us such as:

Contact Information (such as name and email address) if you contact us for support.

Other Information you choose to give us (such as to identify a lost account).

Information we collect automatically or that is generated about you when you play our

Games:

Information regarding your use of the game: such as data about your use of the game, for example, game progress, game actions and gameplay data.

Identifiers: your IP address.

Information we receive from third parties:

Information collected from our advertising partner Google AdMob: device ID and information on your interactions with advertising shown in on our game.

Information regarding confirmation of payment from the google app store when you purchase boosters, coins or bundles in our games we receive confirmation of your purchases from Google Play. The purchase confirmation includes your device ID, confirmation number and details of the boosters, coins or bundles that you purchased.

How we use your personal information

Provide you with the Games: To perform our contractual obligation towards you to allow you to play the Games, we process necessary Information including Information you provide to us when playing the Games, identifiers, information you generate and display when playing the Games, information regarding your use of the Games and information regarding your in Game purchases.

Improve the Games: It is in our legitimate interests to improve our Games for our players. We analyze game play data from all players to balance game difficulty.

Provide you with support and to respond to your requests or complaints: If you reach out to us for support, we will use your Information to open a support ticket, respond to your emails and resolve your queries and complaints and to facilitate support (e.g. retrieval of Game level). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your identifiers, Inrealms specific ID, where you are located and any other information about you collected via our player support channels.

Prevent fraud, enforce our terms and to comply with our legal obligations: It is in our legitimate interest to protect our interests and to keep the Games and their social features safe and fair by (1) analyzing and monitoring Game use to detect fraud or any other user behavior which prejudices the integrity of our Games, (2) taking steps to remedy such fraud and behavior and (3) enforcing our terms and policies. When doing so, we will process the relevant Information, including Information you provide us, Information we automatically collect about you, and Information which is provided to us by third parties.

Who We Share Your Information With

We share your Information with selected third parties, including:

A cloud service provider who we rely on for data storage, which is Google Cloud, with data storage located in United States.

Google Play Store maintains a record of purchases. The information we are provided with includes your device ID and the in app purchase activity to enable us to provide you with the items you purchase.

Law enforcement agencies, public authorities or other judicial bodies and organizations: We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).

Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

Where We Process Your Information

Our service is global by nature and your Information can be collected from players anywhere in the world. Currently your Information is processed by our employees and service providers in the European Economic Area (“EEA”), and the USA.

Your Rights

If you are based in the EEA, Switzerland or are a legal resident of California in the United States, you have certain rights in relation to your Information. For Californian residents, please refer to Addendum 1 – California Privacy Rights. For EEA and Switzerland based, you will find more information below on when which rights can apply.

EEA and Switzerland

Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. This right is not absolute. For example, we cannot reveal trade secrets, or give you Information about other individuals. To exercise this right, please email us at support@inrealms.com with details of what Information you would like access to and include your player ID which is located in the lower left corner of the “Settings” screen of our Games.

Erasure. If you would like us to erase your Information, please contact us at support@inrealms.com. We may need to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defense of legal claims, to respect freedom of expression, or where we have an overriding legitimate interest to do so, but we will let you know when this is the case.

Note that where the Information is held by a third party data controller, such as an advertising partner, we will use reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your Information containing personal data is erased.

Objection and withdrawal of consent. You may have the right to (i) withdraw your consent where you previously provided such consent; or (ii) object to our processing of your Information where we process such Information on the basis of our legitimate interests (see above under How we use your personal information)

Correction. You have the right to correct any Information held about you that is inaccurate.

Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.

Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.

How Do We Protect Your Information

Security Safeguards: In order to help ensure a secure and safe player experience, we are continuously developing and implementing organizational, technical and physical security measures to protect your Information from unauthorized access or against loss, misuse or alteration. These measures include hashing of Information, segregating and limiting access to Information and requiring two factor authentication to access Information.

Retention: We retain your Information for as long as needed to provide you the Games and up to three (3) years from the date on which you stop interacting with the Games.

Contact & Complaints

We welcome questions, comments and requests regarding this Policy. These should be addressed to support@inrealms.com.

If you wish to make a complaint about how we process your Information, please contact us at support@inrealms.com and we will address your request as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority.

Changes

Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you through the Website and in Game. Your continued use of our Website and/or Mobile Games after the effective date of any changes will be subject to the new Policy.

Addendum 1 – California Privacy Rights

The terms of this Addendum apply to residents of California under the California Consumer Privacy Act (“CCPA”) and related applicable laws. Collection and Disclosure of Personal Information Over the past 12 months, through your use of the Games, we may have collected and disclosed the following categories of personal information, as defined in the CCPA, from or about you:

Identifiers, including IP address, advertising ID and Inrealms specific ID. This information is collected directly from you or your device.

Internet or other electronic network activity information, including your use of in-game features and events and information on your in-game activity, and information on your interactions with advertising shown in on our Games. This information is collected from our third party advertising partner.

We collect personal information for the following purposes:

To operate and administer the Games;

To improve the Games;

To communicate with you;

To serve advertising;

For security and verification purposes, including to prevent and detect fraudulent activity; and

To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see How we use your information in the main portion of the Privacy Policy.

We may disclose personal information to the following types of entities:

Other players and users should you choose to share chat data via a Game with a chat feature;

Our affiliate companies within our corporate group who process personal information in order to operate the Games;

Marketing and advertising partners who use your information to serve you ads in the Games and on other sites;

Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us;

Regulators, judicial authorities and law enforcement agencies;

Entities that acquire all or substantially all of our business.

Rights under the CCPA

The CCPA provides California residents with certain legal rights; these rights are not absolute and are subject to certain exemptions. If you are a California resident, and the CCPA does not recognize an exemption that applies to you or your personal information, you have the right to:

Request we disclose to you, free of charge, the following information covering the 12 months preceding your request:

the categories of personal information about you that we collected;

the categories of sources from which the personal information was collected;

the purpose for collecting personal information about you;

the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

the specific pieces of personal information we collected about you;

Request we delete personal information we collected from you; and

Be free from unlawful discrimination for exercising your rights, including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

You can exercise your rights, by emailing us at

support@inrealms.com.