Avia Games Privacy Notice

Last Updated: March 19th, 2025

 

AviaGames, Inc. (“AviaGames”, “we”, “us”, “our”) provides interactive skill-based games. Avia Games respects and values your privacy. This Privacy Notice (“Privacy Notice”) is designed to help the individuals engaging with us from the United States understand how we collect, use, process, and share your personal information, and to inform of you of how to exercise your privacy rights.

 

Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act and California Privacy Rights Act of 2020 (“CCPA/CPRA”), please see Annex A – Supplemental CCPA/CPRA Privacy Notice.

 

Scope. This Privacy Notice applies to personal information processed by us, including on our websites, games, applications (including, but not limited to 8 Ball Strike: Cash Pool, 8 Ball Strike: Win Real Cash, Bingo Bliss, Bingo Clash, Bingo Tour, Blockolot, Bubble Buzz, Pocket7Games, Solitaire Clash, Solitaire Clash infinite, Solitaire Slam, Solitaire Venture) and all other online or offline products, services, and offerings we may provide in the future. To make this Privacy Policy easier to read, our websites, mobile applications, games, and other offerings are collectively called the “Services.”  

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1. UPDATES TO THIS PRIVACY NOTICE

2. PERSONAL INFORMATION WE COLLECT

3. HOW WE USE PERSONAL INFORMATION

4. HOW WE DISCLOSE PERSONAL INFORMATION

5. YOUR PRIVACY CHOICES AND RIGHTS

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

7. RETENTION OF PERSONAL INFORMATION

8. CHILDREN’S INFORMATION

9. OTHER PROVISIONS

10. CONTACT US

ANNEX A – SUPPLEMENTAL CCPA/CPRA PRIVACY NOTICE

 

1. UPDATES TO THIS PRIVACY NOTICE

 

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

 

2. PERSONAL INFORMATION WE COLLECT

 

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

 

       A. Personal Information You Provide to Us Directly

 

We may collect personal information that you provide to us.

 

• Account Creation. To access certain parts of our Services, you may need to create a profile (your “AviaGames Account”). When you create an AviaGames Account for use with our Services, we may collect username, password, country location, and email address. You may also have the option to add a short description about yourself or a profile image, your username, country location, profile image, and description about yourself will be visible to other Users. 

  • You can also access some our Services as a guest, without creating an AviaGames Account. If you use our Services without creating or logging into an AviaGames Account, we will still collect the personal data described in “Information Collected Automatically” below associated with your device identifiers and may also collect include your name and payment information (as described in the “Payment Information” section immediately below), device information, and location. We may connect this information with your AviaGames Account, if you have one, or if you create an AviaGames Account at a later date.

  • Date of Birth: to play cash games, you will need to provide your date of birth, which will be associated with your account.

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• Payment and Financial Account Information. We may collect personal information and details associated with you if you make purchases and withdrawals via our Services and/or to detect illegal or unfair activities (like fraud) that may compromise the integrity of our Services. In addition to the details of the withdrawal and the account information described above, we require first and last name, phone number, and physical address to facilitate withdrawals, and may also require you to provide your government-issued ID (e.g., your social security number or ITIN) for tax purposes if you make significant withdrawals via our Services.

  • We use third-party payment processing companies who process your transactions (which may include PayPal, Apple Pay, etc.), and they may directly collect your first and last name, date of birth, email address, physical address, credit and debit card information, government-issued identification, preferred currency, bank statements, IP address, phone number, and other personal or financial information as needed to verify your identity, and confirm you are legally eligible to make withdrawals from your account.  We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (for example, your billing details)

  • We do not collect biometric information. In connection with our identity verification procedures, you may be required to take a selfie, which our service providers may analyze with your provided government-issued ID to ensure your facial image matches the photo in your government-issued ID.  Your submission of a photo and government-issued ID to our service provider will be subject to that service provider’s privacy policy, and you should review that privacy policy before submitting any personal information.

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• ​Information to Combat Fraud. In addition to the information described above, in some instances, we may also ask you to upload a video of yourself actually playing our games to ensure you are the one playing. We use this information to help us manage risk, prevent fraud, and enhance the security of our Services, and we do not use biometrics for this purpose. 

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• ​Your Communications with Us. We and our service providers may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us.

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• ​Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.

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• ​Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). AviaGames also may collect, use, store, transmit and publicly display statistical data regarding your game play (e.g., scores, rankings, and achievements). Any information you provide using the public sharing features of the Services (referred to in this Policy as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution and discretion before revealing any information that may identify you in the real world to other users. 

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• ​Sweepstakes, Tournaments, Competitions, Contests, or other Events. We may collect personal information you provide for any sweepstakes, tournaments, competitions, contests, or other events that we offer (e.g., name, email address, date of birth). In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

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• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

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• Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

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       B. Personal Information Collected Automatically

 

We may collect personal information automatically when you use the Services.

 

• Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address or precise geo-location information if enabled on your mobile device).

 

• Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit or emails that you open from us, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.

  • Telemetry. When you play our games, we may collect statistics and other information about how you use the Services. This may include information about gameplay, game server usage, game device usage, system interactions, friends you connect with through our Services, and other information associated with your AviaGames Account. We might also record your gameplay, (including your button inputs), and replay it to you or other Users or use it to match with other player(s), improve our Services and prevent fraud. We may also use records of your in-game behavior and skill levels to match you with other players or the recorded gameplay of other player(s).​

  • Crash Reports. We may collect usage details about when you launch our games, when and how long you play each game, and detailed crash reports, which may contain information about the hardware or device you play our games on. 

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• Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.

  • Cookies. Cookies are small text files stored in device browsers. ​

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

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Our uses of these Technologies fall into the following general categories:​

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• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

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• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services;

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• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

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• Advertising or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

 

       C. Personal Information Collected from Third Party Sources

 

Third-Party Websites, Applications, or Platforms. To access some of our Services, you may have the option to link an account on a third-party website, application, or platform, such as Google, Facebook, and Apple (“Third-Party Platforms”) with the Services. Third-Party Platforms are not controlled by us, and their collection and usage of personal data is subject to their respective privacy policies. We may obtain additional information about you from the Third-Party Platforms, depending on your privacy settings.

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Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information with people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

 

ID Verification Partners. We may obtain personal information about you from credit bureaus and identity verification partners.

 

3. HOW WE USE PERSONAL INFORMATION

 

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

 

       A. Provide the Services

 

We use personal information to fulfill our contract with you and provide the Services, such as:

 

• Managing your information;

• Verify your identity in accordance with applicable know-your-customer, money-laundering and other financial sector legislation or regulations;

• Providing access to certain areas, functionalities, and features of the Services;

• Personalizing the Services for you, such as sending you birthday rewards or other benefits;

• Answering requests for support;

• Communicating with you;

• Sharing personal information with third parties as needed to provide the Services;

• Processing your financial information and other payment methods for products and Services;

• Processing applications if you apply for a job we post on our Services; and

• Allowing you to register for events.

 

       B. Administrative Purposes

 

We use personal information for various administrative purposes, such as:

 

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Determining your eligibility to use our Services, including under local law; 

• Carrying out analytics;

• Measuring interest and engagement in the Services;

• Improving, upgrading, or enhancing the Services;

• Developing new products and services;

• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;

• Debugging to identify and repair errors with the Services;

• Auditing relating to interactions, transactions, and other compliance activities;

• Sharing information with third parties as needed to provide the Services;

• Enforcing our agreements and policies; and

• Carrying out activities that are required to comply with our legal obligations.

 

        C. Marketing

 

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

We may engage third-party advertising partners to promote our Services based on your interactions with our Services. Under certain state privacy laws (such as those in California, Colorado, and Virginia), this activity may be considered a 'sale' or 'sharing' of personal information, or 'targeted advertising'.

 

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

 

        D. With Your Consent or Direction

 

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

 

         E. Automated Decision Making

 

We may engage in automated decision making, including profiling, such as to determine your skill level to match you with players of a similar skill level or to determine whether you are permitted to make withdrawals from your AviaGames Account. Our processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making.

 

If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

 

4. HOW WE DISCLOSE PERSONAL INFORMATION

 

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

 

        A. Disclosures to Provide the Services

 

We may disclose any of the personal information we collect to the categories of third parties described below.

 

• Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with identity verification, hosting, customer service, analytics, marketing services, IT support, and related services. We may provide your name and address to our third-party vendor who issues digital and paper checks on our behalf, so we can send you a check for your winnings.  In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.

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•  Some of the service providers we may use include:

  • Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.

 

• Other Users You Share or Interact With. The Services may allow our users to share personal information or interact with other users of the Services, such as your profile or User Content.

 

• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).

 

Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

 

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

 

Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

 

• Affiliates. We may share your personal information with our corporate affiliates.

 

• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.”  

 

       B. Disclosures to Protect Us or Others

 

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

 

       C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

 

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.