PRIVACY NOTICE FOR "Coin Gangster" GAME
—— Aiqi Net Limited

This Privacy Notice will be effective from August 19th, 2022.

Introduction

This Happy Donut Privacy Notice (the “Privacy Notice” or “Notice”) is provided to help you understand our practices regarding how we collect, use, share, and protect personal data. In this Privacy Notice, “Happy Donut” refers to Happy Donut Holding Corp. and its subsidiaries. We may also refer to Happy Donut as "we" or "us".

This Privacy Notice applies whenever you play the games that link to this Notice, or otherwise access any of our other products and social games for the web, mobile, or any other applicable platforms and/or devices (the “Service”). This Privacy Notice does not apply to games offered by Wooga GmbH and Seriously Digital Ltd (both are companies subsidiaries of Happy Donut Holding Corp.); the privacy policies for those games are available on the respective games and the company websites. 

By using the Service, you agree to the collection, disclosure, storage and use of personal data as described in this Privacy Notice. If you do not want Happy Donut to collect, store, use or share the personal data you provide in the ways described in this Privacy Notice, you should not play Happy Donut’s games or use our Service. 

1. Personal Data We Collect

Happy Donut collects personal data to fulfil one or more of its functions and activities, as described in this Privacy Notice.

A.Personal Data That You Share with Us 

When you use our Service (whether through a social network or through Happy Donut directly), you may give us information directly (like when you’re setting up your account or when you contact Customer Support) such as:

• your age or birthday;
• your first and last names;
• your e-mail address;
• a password;
• other information that helps us make sure it’s you accessing your account, information necessary for us to provide the support you request, or information you provide to help us improve our Service (such as answers toan online survey or a feedback form).

When you use our Service, you can choose to create a player profile that other Happy Donut players can see. In your profile, you can include information like:

• a profile photo;
• game username(s);
• your gender;
• biographic details (like your age or age range);
• approximate location information;
• links to your profiles on various social networks;
• details about the games you play.

You can also provide us personal data directly in a number of other ways, including:

• in response to surveys or other research we conduct;
• to participate in contests and sweepstakes; 
• via social media;
• by participating in group communications or chats;
• at conferences, conventions, and other events. 

B.Personal Data That We Get from Others

We may collect or receive information about you from other sources like third-party applications, such as an app store, third party login service, and social networks on which you play our games. We use this information along with information you provide us directly in a number of ways as described in this Privacy Notice, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.

If you play Happy Donut’s games or access any of our Service on connected third-party applications or connect our Service to any third-party applications, including social networks like Facebook, Happy Donut may receive certain information about you from the provider of the third-party application. The information we receive depends on the Happy Donut game you’re playing, the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.

For example, Happy Donut may collect and store some or all of the following information shared by the third-party application:

• your first and last name;
• your profile picture or its URL;
• your user ID number (like your Facebook ID number), which may be linked to other information like your name and profile photo, and your friends’ identifiers;
• the user ID number and other information of your friends, like their names and profile photos;
• the login e-mail you provided to the third-party application;
• your physical location and that of the devices you use to access our Service;
• your gender;
• your birthday and/or age range;
• information about your activities on or through the third-party application;
• other information you have shared on the third-party application;
• any other information that you or the provider of the third-party application share with Happy Donut.
• If you access our Service from a third-party application or connect our Service to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Notice.

If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

C.Cookies and Automated Information Collection

Like many websites, Happy Donut, our service providers and other parties may send cookies to your device when you access or view the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes.Information contained in a cookie may be linked to personal data. We use cookies for purposes such as improving the quality of Happy Donut’s Service, tailoring recommendations to interests, and making the Service easier to use.

Third party advertisers on the Service may also use, place, or read cookies or other technologies as described below on your device, and those practices are subject to their own policies. For more information on how you can opt-out of or disable cookies, please see the Your Rights section below.

We and our service providers may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively by excluding our current players from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-game preferences, and speed up load times.

We, our service providers, and other parties may collect the following information via cookies and other technologies:

• the type of device you are using;
• your device’s operating system and version;
• your mobile device’s identifiers, like your MAC Address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
• your browser type;
• your browser language;
• referring and exit pages and URLs;
• platform type;
• the number of clicks on a page or feature;
• domain names;
• landing pages;
• pages viewed and the order of those pages;
• the amount of time spent on particular pages;
• game state and the date and time of activity on our websites or games.

In some cases, we will connect this information with your social network ID or Happy Donut user ID.

On our Service, we may use Google Analytics or other vendors to collect information about your behavior and demographics. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. You can opt out of Google’s collection and processing of data by going to https://tools.google.com/dlpage/gaoptout .

D.Information You Generate Using Our Communications Features

You may be able to take part in certain activities on our Service that let you communicate or share information with Happy Donut and other players. These include:

• participating in player forums and message boards;
• posting public comments to other players’ profiles or gameboards;
• sending private messages or invitations to other players, either directly on our websites or to their e-mail accounts;
• chatting with other players;
• posting photos or drawings.

You may choose to disclose information about yourself in the course of contributing player-generated content to the Service, including in its chat rooms, blogs, message boards, player “profiles” for public view or in similar forums through mobile services and/or through third-party sites or services, posting public comments to other players' profiles or gameboards, sending private messages or invitations to other players, either directly on our Service or to their e-mail accounts and posting photos. You should consider any information that you disclose in any of these forums as “public”, and you should have no expectation of privacy or confidentiality.

Additionally, you should be aware that any personal data you submit, including videos and images, can be accessed, read, watched, collected, or otherwise used by other players of these forums, and could be used to send you unsolicited messages. Happy Donut is not responsible for the personal data you choose to make public in any of these forums.

We may use any information you share for any purpose as described in this Privacy Notice.

Note that you should consider any information you post or otherwise share with other players through a Service or a third-party site or service as “public” and you should have no expectation that it be kept private.Please also see Happy Donut’s Terms of Service for further information and guidelines about posting content through our Service.

To enable some of the social features, you may be able to import your address book contacts or to manually enter them so that you can locate your contacts using the Service and invite them to join you in our games or other aspects of our Service. You are responsible for getting your contacts’ permission before you give their contact details to us. We may also get information about you from other Happy Donut players importing or entering their contacts.

E.Payment Information

Happy Donut may obtain the billing and payment information that you provide when your purchase is processed by someone else (like Facebook, Apple or Google) such as when you purchase something in a game you play on a social network or that you downloaded on your mobile device. Our   explain our policies and terms relevant to our charges, billing practices, third-party credits and virtual currencies.

If you purchase virtual currency or virtual items in a Happy Donut game, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information.

Happy Donut does not collect or store credit card numbers. However, Happy Donut’s payment processors may share information with us related to your purchases. We may use this information for purposes as described in this Privacy Notice.

If you would like to learn more about how we secure your information, please see Security of Your Information section below.

 2.How We Use Personal Data

Happy Donut uses personal data for a variety of business purposes as described in this Privacy Notice, including to fulfill our contractual obligations, complete transactions you request, comply with law, and for other legitimate business purposes, such as to:

• create your game accounts and allow you to play our games;
• operate, improve, and optimize our Service and our players’ experiences, including by measuring interest in and engagement with our Service;
• process payment card and/or other financial information to facilitate your in-game purchases;
• identify and suggest connections with other Happy Donut players and personalize our Service to you;
• enable players to communicate with each other;
• provide technical support and respond to player inquiries;
• authenticate and/or verify individual identities;
• protect the safety and well-being of our players;
• protect Happy Donut's rights and property in connection with our Service;
• address technical issues and maintain and/or enhance network and information security;
• conduct audits, ensure internal quality control, and take safety precautions;
• prevent and/or prosecute fraud or potentially illegal activities and to enforce our Terms of Service;
• manage and deliver contextual and behavioral advertising;
• notify players of in-game updates, new products, content or promotional offers;
• administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• comply with our legal obligations, resolve any disputes we may have with you or other players, collect any money owed us, and to enforce our agreements;
• conduct research, including by using personal data to create de-identified and/or aggregated data. De-identified and aggregated data are not personal data and we may use and share such data for any legally permissible purposes.

Your interactions with our Service may be tracked across platforms and/or devices.

In addition to the above, if you have provided your e-mail address to Happy Donut, we may use it to communicate with you and other players in a number of ways, including to respond to customer support inquiries; keep you and others informed of your in-game activity, comments from friends, and in-game status and promotions; and tell you about gift and neighbor requests. Some messages, like invitations for friends to join you in a game, may include your name and profile photo. We may also send promotional messages ("Promotional Communications") directly or in partnership with other parties.For more information on how you can opt-out of Promotional Communications, please see the Your Rights section below. 

We may use technologies considered automated decision-making or profiling, but we will not do so in a way that has a legally significant impact on you, unless we have your consent or we are otherwise legally permitted to do so. 

We may also use personal data for any other purposes communicated to you at the point of collection, or otherwise with your consent. 

3. How We Share Personal Data

We may share personal data about you between and among Happy Donut Holding Corp. and its subsidiaries.

Additionally, we may disclose or publish aggregated and analytical information (information about you and other players collectively that is not intended to specifically identify you, for example, players between the ages of 25 and 30 who live Chicago) and other non-personal data about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

In addition, we may share your information (which may include personal data) with third parties (in other words, parties other than Happy Donut) or allow third parties to collect this information from our Service as described in this Privacy Notice.

A.Service Providers

Happy Donut uses its subsidiaries and other unaffiliated companies (“Service Providers”) to support the Service, like processing payments, analyzing data, optimizing game play and enhancing player experience, e-mail delivery, hosting services, managing and delivering contextual and tailored advertisements. 

B.Friends and Other Happy Donut Players

In most Happy Donut games, if you play or register through a social network (for example, Facebook Connect), your social network friends may see your name, profile photo, and descriptions of your game activity. If you use our Service in response to an invitation from another player, that player may see certain information about you and your in-game activities, including when you join and the level(s) you reach within the game. Correspondingly, in many Happy Donut games, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity (including the identification of any Happy Donut games you have played), communicate with you within our Service, and view your game profile, which may include your name or a “game name” and your profile photo. Other players may also be able to send you game requests or even friend requests through the related social network’s or Happy Donut’s communication channels.

C.Third-Party Advertising Including Tailored Advertising and Analytics

We may have advertising on our Service so we can continue to offer our Service for free.

When advertisers or ad networks place ads in our Service, they may collect or we may share the following types of information from within our Service:

• performance data (like the number of clicks on an advertisement);
• aggregated and/or de-identified information about you and other players that is not intended to specifically identify you (like players between the ages of 21 and 25 who live in San Francisco);
• certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and device identifiers);
• your social network ID;
• other contextual data about your game play (for example, your level and session length).

The information collected may be used to:

• measure how effective ads are;
• offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising)
• undertake web analytics (like Google Analytics which is used to analyze traffic and other player activity to improve your experience).

Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time.

Please note, after clicking on a third-party advertisement, you may no longer be on a site hosted by Happy Donut or the social network through which you are playing Happy Donut’s games.

D.Sale or Merger

In the event that Happy Donut undertakes efforts to engage in a business transition ( like a merger, acquisition by another company, or sale of all or part its assets (like selling a game), we may disclose or transfer relevant information we have, including personal data, to the successor organization in the transition. We will make reasonable efforts as described in this Privacy Notice to let you and other players know of the business transition before transferring personal data.

 E. Legal Compliance

 We may share personal data in the following circumstances: 

• when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena);
• to satisfy any laws or regulations;
• where we believe in our sole discretion that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, us, another person or the public generally;
• to protect the rights or property of Happy Donut and other applicable third parties, including to enforce our 

4.Your Rights

Depending upon the applicable law where you live, you may have the right to make requests with respect to personal data that Happy Donut processes about you, for examples:

• for information; 
• for access;
• for correction (or rectification) of personal data that you think is incorrect;
• for erasure (or deletion);
• for an electronic copy (or portability);
• to object to certain processing, including to opt out of targeted advertising.

Happy Donut allows all players to submit the requests via the  or through the Privacy category in the support page within the game you play.

A.Manage Information We Get from Third Parties

To manage the information Happy Donut receives about you from a third-party platform where you play our games, like Facebook, Apple, Amazon etc. you will need to follow the instructions for each such third-party application for updating your information and changing your privacy settings. 

B.Turning off Geolocation

You can stop making geolocation available to us through your device's settings for the relevant application or the “settings” page for the relevant game. If you have previously allowed us to access your geolocation data, we may continue to use that information as described in this Privacy Notice.

C.Opting Out of Promotional Emails from Happy Donut

If you want to stop receiving Promotional Communications from Happy Donut, you can click on the "unsubscribe" link in any promotional email from Happy Donut. If you want to stop receiving texts or SMS messages from you, you can reply “STOP” to any promotional message. Please note that it may take us some time for your opt-out to become effective. 

Additionally, in most of our games, you may find an option under “your account” or “Settings” to request that we stop sending you Promotional Communications.

D.Opting Out of Facebook messages

If you want to stop receiving messages through our game pages on Facebook, you may click on the “settings” icon on the top of such message, and by clicking”manage messages” you may turn off all messages from such game.

E.Opting Out of Push Notifications

When you install our apps on your mobile device, you can choose to receive push notifications, which are messages an app sends you on your device even when the app is not on. You can turn off notifications by visiting your mobile device’s “settings” page.

F.Opting Out of Third-Party Tailored Advertising

In some games that serve third-party ads we provide you a toggle button enabling you to disable third-party tailored ads.

For more information about tailored advertising and your choices to prevent third parties from delivering tailored web and mobile web advertising you can visit  . To opt out, for businesses that participate in the Digital Advertising Alliance, you can exercise that option at   and  . 

If you live in the EU, you can get information and exercise your choices at  . 

These opt-out tools are provided by third parties, not Happy Donut. Happy Donut does not control, operate, or endorse these tools or the choices that advertisers and others provide through these tools. They are listed here only as a convenience for players.

In addition, if you do not want to receive third-party tailored in-application advertisements, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the “Advertising Identifier” (like an IDFA) from your device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not Happy Donut. Happy Donut does not control, operate or endorse these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive advertisements from third parties within Happy Donut’s games even if you opt out of tailored advertising but they will not be based on your activity across unrelated web sites or apps.

G.Opting Out of Cookie Tracking

You can set your web browser to warn you about attempts to place cookies on your device or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the   and make changes at the  .

If you disable cookies, you may lose some of the features and functionality of our Service because Happy Donut cookies are necessary for providing the Service.

H.Do Not Track

Note that Happy Donut does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.

 5.Children’s Privacy

For Slotomania, House of Fun, Caesars Casino, Vegas Downtown Slots, World Series of Poker, Poker Heat, and/or Bingo Blitz, you may not use the Service if you are under 21 years of age, in which case you must not create an account, access, use or download such games and/or submit any personal data through the Service and/or to Happy Donut. For all other Happy Donut Service, you may not use the Service if you are under 18 years of age, in which case you must not create an account, access, use or download such games and/or submit any personal data through the Service or to Happy Donut. Happy Donut is committed to complying with laws protecting children. If you believe that your child has submitted personal data to Happy Donut without your consent, please contact us at . Happy Donut will take reasonable steps to delete such information as soon as possible.

6. International Transfers, Retention, Security, Links, Updates, and How to Contact Us

 A.  International Transfers 

When you use our Service, your personal data may be sent, accessed, used, and/or stored outside of the country or region where you live including, for example, to the United States and Israel. We may transfer personal data to our subsidiaries, vendors, business partners, and others as described in this Privacy Notice, and by using the Service you consent to such transfer.

Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in place where you live. When we transfer personal data outside of the location where it was collected, we put into place appropriate safeguards (including, for example, contracts) or otherwise ensure that such transfers meet applicable local legal requirements. 

B. Retention 

We will retain personal data for as long as you use the Service and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.

C. Security 

We take reasonable steps designed to protect personal data; however, no system or network can be guaranteed to be 100% secure and therefore we cannot guarantee the security of data. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure. 

D.  Links to Other Sites/Apps

Happy Donut Service may include links to other websites and/or applications that are owned and/or operated by others. Any information you provide on such websites and/or apps are subject to the privacy policy on such website or app and Happy Donut is not responsible for the content, privacy policy, terms of use, or security practices of such site and/or app. You should review the terms and privacy policy of any site or app that you access.

E. Updates

Happy Donut reserves the right to amend the Privacy Notice from time to time, and Happy Donut encourages you to consult the Privacy Notice regularly for changes. 

If we make material changes to our Privacy Notice, we will tell you and other players by placing a notice on Happy Donut.com or its equivalent in-game, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other Happy Donut websites. You should periodically check   and this privacy page for updates.

F.How to Contact Us

If you have any questions, comments or concerns about our Privacy Notice or any other privacy issue please contact Happy Donut’s DPO at   or Chief Privacy Officer, 8 Hachoshlim St., Herzliya Pituach 4672408 Israel.

If you want to exercise your rights you can submit a ticket via the applicable support channel of the game or through the  .

For players in the EU, we have appointed Homerun Ciero S.R.L. (Romania) as our EU representative. You can address any questions or concerns you have either as described above or to our EU representative at Homerun Ciero S.R.L. TN Offices 3 on the 1st floor, 165 Splaiul Unirii, Bucharest, Romania.

Additionally, if you have any questions or concerns that you think we have not adequately addressed, you may have the right to bring your question or concern to the privacy authority in the location where you live.  

7. Supplemental California Consumer Privacy Act (CCPA) Notice ("CCPA Notice”) 

Happy Donut uses and shares information as described in this Privacy Notice. The information below supplements the Privacy Notice and is intended for California consumers only. 

Collection and Use of Personal Information

"Personal Information" in this CCPA Notice, as in the CCPA, refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a certain consumer or household.

The following chart lists the categories of Personal Information we collect about players, the source of collection, and the business purposes for collection, all in accordance with the categories of Personal Information and business purposes enumerated in the California Consumer Privacy Act of 2018 (CCPA). These are also the categories of Personal Information we collected in the past 12 months and their business purposes. 

A more detailed description of the particular pieces of information we collect and their purposes is provided in this Privacy Notice.

Category of Personal Information	Categories of Sources	Commercial or Business Purpose
Identifiers, such as picture, account name, device ID, email address, IP address, etc.	Players Players’ Devices Data Services Service Providers	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition
California Customer Records (Cal. Civ. Code § 1798.80(e)) such as telephone number and payment information	Players Data Services Service Providers Social Network Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition
Protected Classification Characteristics, such as age and gender	Players Service Providers Social Network Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing Detecting/Protecting against security events Player acquisition
Commercial Information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Players Data Services Service Providers Social Network Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing Detecting/Protecting against security events Player acquisition
Internet/electronic Network Information, such as website or application or advertisement browsing history	Players Players’ Devices Data Services Service Providers Analytic Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition
Location Data, device shared location, and Wi-Fi connection location	Players Players’ Devices Data Services Service Providers	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition
Inferences such as derivation of information, data, assumptions, or conclusions from any of the above categories of personal information	Players Players’ Devices Data Services Service Providers Social Network Services Analytic Services	Customer support Internal analytics and reporting Internal research Operate our business and games Game mechanics or functionality Facilitate players' social interactions Debugging existing intended functionality Product development / improvement Maintaining and enhancing service Auditing Player interaction & transactions Advertising and marketing  Detecting/Protecting against security events Player acquisition

Happy Donut permits, under cerein legal and technical limitations, certain third-party advertising partners to collect information about our players through our games and our website for purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for ad fraud detection and reporting. To the extent this practice is interpreted to constitute a "sale" under the CCPA, please see our Online Advertising section below for more information.

To Whom We Disclose Personal Information

As described in this Privacy Notice, we share personal information within the Happy Donut group of companies and with a variety of recipients for business purposes.

In addition to the categories of recipients identified in the How We Share Personal Data section of this Privacy Notice, we disclose personal information to, or allow access to personal information by, the following categories of recipients:

• Cloud Storage Providers
• Payment and Auditing Processors
• Security Safety Vendors and Service Providers
• Customer Service Vendors
• Advertising and Marketing Partners

Online Advertising

The following describes the categories of personal information we sell for a business purposes, in accordance with the categories of Personal Information enumerated in the California Consumer Privacy Act of 2018 (CCPA). These are also the categories of information we sold in the past 12 months.

When we serve you personalized video ads, we sell your resettable identifiers provided by your mobile device’s operating system with ad networks, social media companies and other third-party businesses in the ad ecosystem. The typical resettable advertising IDs are GAID (Android) and IDFA (Apple) and they are considered personal information under the CCPA. These third parties use your personal information to:

• serve relevant ads on our site, on other websites or mobile apps, or on other devices a Player may use;
• to personalize content; and
• to perform other advertising-related services such as reporting, attribution, analytics and market research.

In addition, in some instances, these third parties may use the information for their own purposes and in accordance with their own privacy policies and terms of use, which may include providing this information to additional third parties, including other advertising networks. Happy Donut provides opportunities, where appropriate, for players to opt-out of the use and sharing of personal data about them for this purpose.

You may reset these identifiers from within your mobile device or limit ad tracking for your mobile device as mentioned above. Alternatively, if you would like to opt out of personalized advertising in our games, please visit the  or you may also do so in the Advanced Settings of our games by changing the personalized/ tailored ads toggle to “off”. If you opt-out, you’ll still see ads, but they’ll most likely be less relevant.

Additional California Rights 

As a California resident, you may be able to exercise certain rights with respect to personal data we have about you. 

Right to know. You have the right to know the following, which we will provide to you after we receive a verified request from you:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting personal information;
• The categories of third parties with whom we share personal information, if any; and
• The specific pieces of personal information we have collected about you.

Right to deletion. Subject to certain exceptions set out below, on receipt of a verified request from you, we will:

•   Delete your personal information from our records; and

•   Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

•   Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

•   Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

•   Debug to identify and repair errors that impair existing intended functionality;

•   Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

•   Comply with the California Electronic Communications Privacy Act;

•   Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

•   Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

•   Comply with an existing legal obligation; or

•   Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

 

To exercise these rights, you can submit a request to exercise your rights in the  or through the Privacy category in the Support page within the game you play. You have the right to not be discriminated against for exercising any of your rights. Please understand that, if the exercise of your rights limits our ability to process personal data (such as a deletion request), we may no longer be able to provide you with the Service.

“Shine the Light”

As a California resident, you may have the right to know how personal data about you is disclosed to third parties for their direct marketing purposes. To request this information, send an email to  with the subject line “California Shine the Light”. 

As provided by law, we may need to verify your identity before processing your request. Although we try to limit the personal data collected in connection with a request, certain requests may require us to obtain additional personal data from you. In certain circumstances, we may decline a request to exercise rights, particularly where we are unable to verify your identity.

Minors

As described in our Privacy Notice, we do not knowingly collect or sell personal data about children.

Authorized Agents

You may be allowed to use an authorized agent to submit requests on your behalf, if you provide sufficient information to show that the requestor is an authorized agent with written permission to act on your behalf and you verify your identity with us.

Service Difference

In each of the following instances, which we occasionally offer on some, but not all games, we may grant you virtual currency or other virtual items within the game:

Service Difference	Categories of Personal Information Collected	How to Opt-In to the Service Difference, if and when offered
In-game videos	Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn	Watch in-game videos that may be presented to you
In-game tailored ads	Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn	Consent to be served with ads that are tailored to your personal information and to sharing your personal information with ad networks, social media companies and other third-party businesses in the ad ecosystem
In-game surveys	Identifiers, protected classification characteristics, commercial information, Internet or other electronic network activity information, location data, inferences drawn	Complete a survey that may be presented to you about you and your game experience
Reviews about the game	Identifiers, location data, inferences drawn	Follow the instructions that may be presented to you to submit a review about the game, or rate the game, in an application store such as Google Play
Facebook connect	Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn	When offered to you, connect to our games through your Facebook account
In-game friend invitations	Internet or other electronic network activity information, commercial information, location data, inferences drawn	Invite your friends to download and play the game by sending an invitation from within the game, if prompted to do so
Connect to our game	Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn	Connect to play the game at the frequency indicated to you
Join our Facebook bot	Identifiers, Internet or other electronic network activity information	Connect with us through our Facebook bot
Mailing list	Identifiers	Subscribe to our mailing list when promoted

 

You have a right to withdraw from the service difference at any time. To do so, please submit a request through the  or via the Privacy option available in the Support section in the game settings.