Last modified: December 4th, 2023

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AviaGames, Inc. (“AviaGames”, “we”, “us”) provides interactive skill-based games. Avia Games respects and values your privacy. This Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use, and share your personal information, and to inform of you of how to exercise your privacy rights.

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1......... SCOPE

2......... PERSONAL INFORMATION WE COLLECT

3......... HOW WE USE YOUR INFORMATION

4......... HOW WE DISCLOSE YOUR INFORMATION

5......... YOUR PRIVACY CHOICES AND RIGHTS

6......... SECURITY OF YOUR INFORMATION

7......... INTERNATIONAL DATA TRANSFERS

8......... RETENTION OF PERSONAL INFORMATION

9......... SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

10....... SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

11....... CHILDREN’S INFORMATION

12....... OTHER PROVISIONS

13....... CONTACT US

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1. SCOPE

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This Privacy Policy applies to personal information processed by us, including on our websites (https://www.pocket7games.com/), games, applications (including, but not limited to, Pocket7Games, Cooking Clash, Bingo Clash, Bingo Tour, Solitaire Clash, 21 Gold, Bubble Shot, Tile Blitz, Dunk Shot, Fruit Frenzy, 2048 Blitz, Word Clash, Match n’ Flip, Yatzy Craze, Blockolot, Bubble Venture, 8 Ball Strike, Bubble Buzz, Bubble Flow, Match N’Flip, Wordcash Search and Explodocube) 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.”

If you have questions regarding our Privacy Policy, please refer to “Contact Us” below.

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2. PERSONAL INFORMATION WE COLLECT

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We collect personal information from our website and mobile application customers (“Users”). The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law.  We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

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A. Information You Provide to Us Directly

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We may collect the following personal information that you provide to us:

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• 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 applications and games, 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.

• 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 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. The third-party payment processing companies who process your transactions (which may include PayPal, Apple Pay, etc.) 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 may also directly collect all of the foregoing information (including first and last name, date of birth, email address, physical address, payment information, and credit and debit card information) for anti-fraud purposes.  

  • Biometric Information. In connection with our identity verification procedures, you may be required to take a selfie with your government-issued ID, which our service providers may analyze to ensure your facial image matches the photo in your government-issued ID. If you consent to our collection of biometric information, you agree that we may collect your image, including your image on your government-issued ID. Your biometric information may be shared with our service providers who may perform a scan of your facial geometry to provide identity verification services to us. Where required by law, we will delete your biometric information within 3 years from your last interaction with our Services.

• 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 playing our games to ensure you are the one actually playing. We use this information to help us manage risk, prevent fraud, and enhance the security of our Services.

• Your Communications with Us. We 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.

• 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.

• 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.

• Sweepstakes, Tournaments, Competitions, or Contests. We may collect personal information you provide for any sweepstakes, tournaments, competitions, or contests 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.

 

B. Information Collected Automatically

We may collect personal information automatically when you use our Services:

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• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, WiFi routing information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our 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.

• Location Information. To participate in some of our cash games or otherwise use certain features of the Services, we may collect precise geolocation data (e.g., GPS coordinates) from your mobile device.

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our 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;

• 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 (see Analytics below);

• 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;

• 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.

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

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• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include Google Analytics. We may use analytics services provided by Google Inc. This allows us to process usage data to better understand how our website and web-related Services are used. This also enables us to continually improve our website, making it relevant to your interests and needs. This may involve personal data, such as cookie and other device identifiers. The data collected by Google Analytics is usually transferred to a Google server in the USA and processed there. In addition, Google uses your data for its own purposes, e.g. for profiling or linking it to other data. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

• Social Media Platforms. Our Services may contain social media buttons, such as Facebook, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address and which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

 

C. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations.

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• 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 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 send content from our Services with people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

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3. HOW WE USE YOUR INFORMATION

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We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

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A. Provide Our Services

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We use your information to fulfil our contract with you and provide you with our Services, such as:

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• Managing your information and accounts;

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

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

• Answering requests for customer or technical support;

• Communicating with you about your account, activities on our Services, and policy changes;

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

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

 

B. Administrative Purposes

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We use your information to analyze and improve our Services in our legitimate interest, or to comply with our legal obligations, such as:

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• 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; 

• Measuring interest and engagement in our Services;

• Short-term, transient use, such as contextual customization of ads;

• Improving, upgrading, or enhancing our Services;

• Developing new products and Services;

• Ensuring internal quality control and safety;

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

• Debugging to identify and repair errors with our 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

• Other uses as required to comply with our legal obligations.

 

C. Marketing and Advertising our Products and Services

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We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law, such as:

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• Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services; and

• Email campaigns, custom audiences advertising and “interest-based” or “personalized advertising.”

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If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

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D. Other Purposes

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We also use your information for other purposes as requested by you or as permitted by applicable law.

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• Anti-Fraud. We may use third-parties to promote our anti-fraud efforts or other activities so that we ensure the integrity of the game play and your use of our Services.  We may share your credit card or financial account information and related personal information with these third parties, if applicable.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

• Automated Decision-Making. We may engage in automated decision making, including profiling,  for example to determine your skill level, to match you with players of a similar skill level, and to determine if 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 significantly affects 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.

• De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. If we create or receive personal data that has been de-identified or aggregated, we will not attempt to reidentify it, except to comply with applicable law.

• Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps in order to prevent fraud. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this, our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

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4. HOW WE DISCLOSE YOUR INFORMATION

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We disclose your information to third parties for a variety of business purposes, including to provide our 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.

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A. Disclosures to Provide our Services

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The categories of third parties with whom we may share your information are described below.

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• Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. For example, 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.  We may also provide your email, phone, IP address and card member name to our third-party vendors for example so they can authenticate your identity, confirm your eligibility to receive payments, and process your deposits. We also share information with service providers that provide us with IT support, hosting, payment processing, fraud prevention and/or “Know Your Customer” verification, customer service, and related services.

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• 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 to business partners with whom we jointly offer products or services.

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• Affiliates. We may share your personal information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you, or to support and supplement the Services we provide.

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• Other Users/Website Visitors. As described above in “Personal Information We Collect,” our Services allow you to share your Profile and/or User Content with other Users/publicly, including to those who do not use our Services. 

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• 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” or “personalized advertising.”

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• APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

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B. Disclosures to Protect Us or Others

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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.

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

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If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

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5. YOUR PRIVACY CHOICES AND RIGHTS

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Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

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• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).

• Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

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The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. 

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Please note you must separately opt out in each browser and on each device.

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Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);

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• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

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• Request Deletion of your personal information;

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• Request Restriction of or Object to our processing of your personal information including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes; and

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• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

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If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

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6.SECURITY OF YOUR INFORMATION

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We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected, and take steps to require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

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By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

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7.INTERNATIONAL DATA TRANSFERS

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All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

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8.RETENTION OF PERSONAL INFORMATION

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We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

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9.SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

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This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information AviaGames has collected about them, and whether AviaGames disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below: