Global Worldwide Inc. Privacy Policy

Last Updated February 1, 2024

I. Introduction to Our Privacy Policy – Our Commitment to Privacy Principles

Global Worldwide Inc. ("we," “us,” “our,” or "GWW") is serious about games. And we are serious about your privacy and data rights. We are committed to maintaining a relationship of trust and transparency with you. This Privacy Policy is written in plain language to make it easy to understand how we collect, use, store, and share information that is identifiable to you ("Personal Data") when you access our websites, mobile applications, games, forums, or other services (collectively the "Service(s)"). When you use a Service, you consent to each of the collections, uses and disclosures of information (including recording and tracking) described in this Privacy Policy. Please read it carefully. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE ANY SERVICE.

II. What Information/Personal Data Do We Collect?

A. Information You Provide to Us Directly. When you interact with a GWW owned website, or download the Service from “Social Network(s)” – which is what we call in this Privacy Policy a social media network / third-party app store (including Facebook, Apple iTunes, Google Play etc.) -- we will collect and store information from you directly as described below, to the extent it is available to us. We collect the information that you give us, that may include your:

Name
E-mail address
GWW account information, such as unique user-name, ID or avatar
Your ID from various Social Networks
We may also offer you the option to complete a user profile that is visible to other Service users. Your user profile may include: an avatar; one or more Service username(s); other optional data.
Limited payment or billing records from Social Network(s) where your Service-related transactions may occur
Your messages to us or the Services (chat logs, customer support requests)
Information that helps us verify it’s actually you, prevent fraud, develop and improve our Services

B. Automatically Collected Information. We collect other information automatically from your device through cookies and other means (SDKs, tracking pixels etc.) when you use our Services, including, to the extent it is available:

IP Address
General Location Data Device information (such as device type, model, operating system, browser version, or unique device identifiers for checking device compatibility and IDFA or GAID)
IDFA means Identifier for Advertisers on Apple and GAID means Google Advertising Identity. These unique identifiers are non-permanent and non-personal, meaning they do not contain sensitive information about you but does allow for consistency across all apps and cross-app tracking. You can opt-out of sharing your device identifier by updating the settings on your device.
Service communications (in-game messages, chat logs)
Connection type

C. Information Given to Us by Third Parties. We may be given access to certain information collected from you by third parties, including Social Networks, through your use of such third party’s services, websites, applications, or other services.

D. We will create and assign to your device an identifier that is similar to an account number. We may also collect / associate the following information about you, to the extent it is available:

Device type; model; operating system; memory; storage;
Country, region, city (determined by IP address);
User name;
Language;

When you use our Services, we will collect information about the ways in which you use and interact with our Services, such as when and for how long your device is logged into our games, game features you access and other players you interact with, in-app purchases you make, progress or levels you achieve, and other gameplay activities.

We also collect pseudonymous usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files, mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number(s).

E. Information Gathered Through your participation in Communities

When you use the Service, you will get access to the online gaming community within the Service which gives you the opportunity to communicate or share information not just with us, but also with other users of our Service through:

Participating in player forums and message boards;
Posting public comments to other users’ profiles or game boards;
Sending private messages or invitations to other users in the Service
Chat with other users; and

When you participate in online gaming communities in the ways described above, we access and store information / Personal Data about you. The information we store varies by application and is affected by the privacy settings you and your friends establish in that application. You can control and find out more about these settings within the application. We will collect the following information:

Your in-Service username;
Your device advertiser ID;
Depending on how you log into the Services, Facebook User ID;
The IP address of your access devices;
Your in-game chats and messages; and

F. Payment information

We will also collect some purchase information (which is comprised of transaction history, including what you have purchased, the price, and the date). Note that your in-app purchase transactions are processed by third-party payment processors, such as Apple (for purchases on iOS devices), Google (for purchases on Android devices). These third-party payment processors do not share your financial information, like credit card numbers, with us.

G. Customer Support correspondence

When you ask for assistance from our Customer Support team, we will collect and store:

Your name (if provided) and e-mail address;
Information about your activity on the Service;
Your user name or ID number; and
Any correspondence connected to the assistance provided to you

H. Information we Never Collect. We do not collect any "special categories” of information from or about you. That is racial data or information regarding ethnic origin, sexual practices or orientation, political opinions, religious or philosophical beliefs, union membership, or health data etc.

III. How and Why Do We Use this Information / Personal Data?

We use your Personal Data and non-personal information to:

A. Provide you with our Services.

Communicate with you according to your preferences, and our Terms of Service.
Operate, develop, maintain, and improve our Services.
Provide customer support for the Services.
Resolve disputes and enforce our Terms of Service.
Make special/promotional in-game offers available to you
Track fees, payments, and other amounts due in connection with the Services.
Enable you to connect with other players.
Create a user account to use the Services.
Provide you with the appropriate version of the Services, including in your preferred language.
Identify, fix, and troubleshoot bugs and service errors.
Develop new services.

B. Secure our Services.

Identify and/or prevent fraud.
Identify and/or prevent Terms of Service violations, illegal activities or cheating.
Verify user identities for customer support communications.
Monitor, ensure and enhance the security of our network and information systems.

C. Personalize our Services or Offer Promotions.

Provide you with notices, personalized game and other offers.
Communicate with you regarding your areas of interest and respond to your requests.
Serve, optimize and measure the effectiveness of our marketing campaigns.
Perform analytics for internal marketing and demographic studies to develop, improve or personalize the Services.
Save, track your game attributes, progress and stats.

D. Legal/Other.

Comply with legal obligations.
Exercise, establish, or defend our Terms of Service and other legal rights.
Instances in which we have a good faith belief of a need to protect the safety, financial or important interest of you, us or any other person.

IV. Who Do We Share this Information / Personal Data With?

Except as described below, we will not share your Personal Data with unaffiliated third parties without your consent. However, we may share non-Personal Data, including anonymized, aggregated, or pseudonymized data in accordance with this Privacy Policy. We may share your information, including Personal Data to third parties in the following instances:

A. Third Party Service Providers. We may contract with third parties to collect or process your information or Personal Data on our behalf to provide the Services such as hosting providers to store the Personal Data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you, email delivery services, and analytics companies. Our agreements with such third parties require them to protect the confidentiality and security of your Personal Data and information in line with this Privacy Policy. We do not share Personal Information with any third parties so they can market to you, without your consent.

B. GWW Affiliated Companies. We may share your information amongst our subsidiaries, parents, or affiliated companies to deliver and/or improve our Services.

C. A Successor of Acquiring Third Party. If GWW is merged with a third party, acquired, purchased (in full or in part), experiences a divestiture, reorganization, bankruptcy, or similar event, information collected under this Privacy Policy may be shared with such third party. We will notify you if this happens.

D. As Required by Law. We may disclose Personal Data if we have a good faith belief we are obliged to do so to:

Comply with a legal obligation.
Protect and defend the rights or property of GWW, users of the Services, or others.
Protect the personal safety, financial or vital interest of users of the Services or the public.
Protect against legal liability.
Monitor compliance with & enforce our Terms of Service, policies, or forum/community rules.
Respond to lawful request by public authorities, including national security or law enforcement agencies.

V. How do we Store and Protect Your Personal Data?

A. Protecting your Personal Data. We implement reasonable security measures to protect the security of your information both online and offline, and we are committed to the protection of customer information. While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Unfortunately, the transmission of information over the Internet is not completely secure. Although we strive to protect your Personal Data, we cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If your account is hacked, this may lead to unauthorized access to your account, so please keep your account information secure.

B. Storing your Personal Data. Personal Data we collect, is shared with us, or is processed under this Privacy Policy may be stored in the United States or any other country in which we, our subsidiaries/affiliates, or third-party service providers operate, including through the use of cloud storage. By using the Services, you consent to the transfer of your Personal Data and non-Personal Data to the United States and other countries which may not offer the same level of privacy protections as the laws in your country of residence or citizenship. As a result, your information could be accessed by foreign governmental authorities, or otherwise, in accordance with applicable local laws.

VI. Your Privacy Controls

You have control over the collection and use of your Personal Data. You may at any time access or correct your Personal Data, restrict collection or processing of your Personal Data, and in some cases, request the deactivation or permanent deletion of your Personal Data. To request access, correction, restriction, deactivation, or deletion of your Personal Data, contact us at privacy@globalworldwide.com. Before we process any request, we may ask that you verify your identity to protect your privacy. This may include communication via the Services platform or other methods of identity verification.

Requests that are unverified, unreasonable or impractical may be rejected, consistent with our legal obligations. To protect your account, requests for deactivation or deletion of Personal Data require additional verification, which may include a temporary suspension of your account and the Services. Once requests for deactivation or deletion are processed, they are permanent, and the Personal Data and account cannot be restored.

“Do Not Track” / “Global Privacy Control”

Do Not Track (“DNT”) is a privacy preference that players can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which you can learn more about at https://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if our site detects a GPC signal from your device, we will interpret it as a request to opt out of selling or sharing your personal information and to opt out of targeted advertising under applicable state law. We will also interpret it as a request to limit the sale or sharing of personal information for targeted advertising for residents of the European Economic Area, the UK, and Brazil.

VII. Children Under Age 13

Our Services are not directed, or intended to be attractive, to children under the age of 13. We do not knowingly collect Personal Data, personal information, photos, videos, audio files, or location data of or from children under the age of 13 or knowingly use persistent identifiers to recognize children under the age of 13 over time and across different websites or online services. If you are under the age of 13, do not use our Services and do not submit any information to us. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Privacy Policy by instructing their children under the age of 13 never to use our Services. If you have reason to believe that a child under the age of 13 has provided Personal Data or personal information to GWW through our Services, please contact us at privacy@globalworldwide.com, and we will take steps to delete that information from our databases as soon as possible.

VIII. Third Party Privacy Policies & Practices / Social Networks

This Privacy Policy applies only to Personal Data and information collected by GWW through your use of our Services. Third-party websites may be accessible through links when using our Services. These third-party websites are governed by their own privacy policies, and we are not liable or responsible for any content appearing on those websites or any privacy or security practices for those websites. To manage the information GWW receives about you from Social Networks, you will need to follow the instructions at that site for updating your information and changing your privacy settings. The privacy management tools for applications on Apple can be found at http://www.apple.com/privacy/manage-your-privacy/. The privacy management tools for Google can be found at https://www.google.com/safetycenter/everyone/start/. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of each application.

Once GWW receives your information from Social Networks, that information is stored and used by GWW in accordance with this Privacy Policy, and you may access and update that information as described below. Service or other accounts created with GWW are considered active until we receive a user request to delete them or deactivate them.

§ Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other 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.

IX. Data Retention / Effect of Deletion Requests

We strive to retain only as much Personal Data as is necessary. When Personal Data is no longer required under this Privacy Policy, we will periodically delete it or de-identify it. When it is not commercially reasonable to delete or de-identify your Personal Data, we will remove your Personal Data from processing and securely store it until we are able to permanently delete it. Please note that we may retain information needed for legal and accounting purposes, to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints. For example, we may retain records pertaining to payments or customer service matters. If you have sent or posted content on the Service, we may not be able to delete it. Complete and effective deletion may require actions on your part such as uninstalling / deleting content related to the Service from your device and/or removing / de-linking the Service from your Social Network(s) account(s). Please note that if ask us to delete your account all your progress in the game and any unused virtual goods will be lost to you and we will not be able to restore them in the future. However, results and artifacts from your in-game play, e.g. kingdoms, bases, characters etc. may remain live in the game even after your account and/or personal information has been deleted or dissociated from the game.

X. European Countries’ Users

If you are located in a country in the EEA, the United Kingdom, or Switzerland,, we rely upon the following bases when processing your Personal Data:

Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our games, customer services, and chat functionality;
Legal Obligation. This covers data used by us to comply with legal obligations, such as to maintain records relating to tax or to respond to valid legal requests for certain data;

· Consent. In cases where we process data based on your consent, we will ask for your explicit consent. You may withdraw consent at any time, but that will not affect the lawfulness of the processing of your Personal Data prior to such withdrawal. While you can withdraw your consent or object to certain types of processing at any time, please note that if you continue to access the Service we will still collect some Personal Data about you and process it as otherwise described in this Privacy Policy. If you do not want us to collect any Personal Data about you at all, you should cease all game play and stop using our Services.

Legitimate Interests. This covers data used by us for purposes that can be reasonably expected with your use of our Services and that we do not believe are adverse to your privacy, such as analytics to understand how our users access and navigate our website and apps, to keep our website and apps safe and secure, research and optimization of the Services, to provide a more personalized experience etc.

XI. European Countries Users’ Rights

If you are located in the EEA, the United Kingdom, or Switzerland, you have certain rights in relation to the Personal Data we hold about you, but which are subject to exemptions under applicable data privacy laws. Some of these only apply in certain circumstances as explained below. In connection with your exercising your rights, we may require you to verify your identity. We will respond to a request by you to exercise those rights without undue delay and within one month. To exercise any of your outlined rights, please send an email to privacy@globalworldwide.com.

We may decline to process requests in certain circumstances, such as where requests are manifestly unfounded, excessive requests, or requests that may jeopardize the privacy of others.

A. Deletion

In some circumstances, you may request that we delete some of your Personal Data. Should you wish to have your personal information deleted, please contact us at privacy@globalworldwide.com.

To effectively process your request, you must delete GWW games from your mobile devices and clear related cookies from any device where you have played GWW games. When we delete any information, it will be deleted from our active databases but may remain in our archives. Please note, however, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form. See “Data Retention Impact of Deletion” above for more information about requests for deletion.

B. Access and portability

You have a right to know what information we hold about you, subject to certain legal exceptions. If you wish to exercise this right please contact us at privacy@globalworldwide.com and let us know that you wish to exercise your right of access and precisely what information you are requesting. We may not be able to provide all the information you ask for in certain cases, for example if the information includes personal information about another person.

You may request the data we process based on consent or to perform our contract with you in a structured, commonly used and machine-readable format or to request we transfer such Personal Data to another party. GWW is not responsible for the security of the Personal Data or its processing once received by the third party.

We also may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person or our trade secrets or intellectual property) as permitted under applicable data protection rights.

C. Correction

You have the right to correct any Personal Data we have that is inaccurate. Where you request correction, please explain in detail why you believe the Personal Data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required.

D. Restriction of Processing

You have a right to require us to stop processing the Personal Data we hold about you other than for storage purposes in certain circumstances, e.g. while we are considering whether it should be corrected or deleted or, based on your objection, whether we should permanently stop processing. Please note, however, that if we stop processing the Personal Data, we may use it again if there are valid grounds for us to do so (e.g. for the defense of legal claims or for another’s protection).

E. Objection

You have the right to object to our processing of data about you other than where required to perform under our Terms of Service, e.g. in order to send you promotions and special offers marketing.

You also have the right to object to our processing of data about you by emailing us at privacy@globalworldwide.com if we are processing the data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

F. Complaints

If you wish to make a complaint about how we process your Personal Data, please contact us at privacy@globalworldwide.com and we will endeavor to respond to your concerns. You always retain your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

XIII. EU / UK Representation

EU Representative: We are based in the United States and as such under Article 27 of the GDPR we are required to provide a contact that will act as our representative should you wish to contact us. You can contact our Representative to exercise your rights under the GDPR or to discuss any sort of data protection issue relating to our company. Our nominated EU Representative is:

Instant EU GDPR Representative Ltd.
Adam Brogden contact@gdprlocal.com
Tel +35315549700
INSTANT EU GDPR REPRESENTATIVE LTD

Office 2,
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8
Ireland

____________________

Our UK Representative:
Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent.

Our nominated UK Representative is: GDPR Local Ltd.
Adam Brogden contact@gdprlocal.com
Tel +44 1772 217800
1st Floor Front Suite
27-29 North Street, Brighton
England

For more information about your rights please refer to: https://gdpr-info.eu/chapter-3/

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@globalworldwide.com.

International data transfer

Your personal information might be transferred to a country outside the EEA, the United Kingdom or Switzerland, 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.

If we transfer personal information which originates in the EEA, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses or similar contractual safeguards, and, if necessary, the implementation of further technical and organizational measures.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. By using the Service you are consenting to, and accepting the risks associated with the transfer of your Personal Data and non-personal data to the United States and other countries which may not offer the same level of privacy protections as the laws in your country of residence or citizenship. As a result, your information could be accessed by U.S. and other foreign governmental agencies and authorities, or otherwise, in accordance with applicable local laws including local laws authorizing mass and/or covert digital surveillance.

XIV. Additional Information for Residents of California, Virginia, Connecticut, Utah, and Colorado

Information We Collect, Use, and Disclose

All sources of personal information collected are noted in the “Information We May Collect and How We Collect It” section above and retained pursuant to “Data Retention” above. The purposes for our collection of this information are described in “How We Use Information” above.

In the past 12 months, we have disclosed (or have enabled you to disclose) the following categories of personal information to third parties for business or commercial purposes:

CATEGORY	CATEGORIES OF PARTIES TO WHOM INFORMATION IS DISCLOSED	CATEGORIES OF THIRD PARTIES TO WHOM INFORMATION IS SOLD AND/OR SHARED
Identifiers and contact information, including first and last name, email address, phone number, home address or shipping address, and your friends’ names and contact information.	Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use) and payment processors. Affiliates for purposes of business operations and support.	N/A
Identifiers such as username or handle, third party service ID, IP address, unique device identifier, advertising identifier, device serial number.	Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use) and payment processors. Affiliates for purposes of business operations and support. Other players in multiplayer games (username only).	Analytics providers
Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream information.	Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use). Affiliates for purposes of business operations and support.	Analytics providers.
Commercial information, such as information regarding in-game purchase payment method.	Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners. Affiliates for purposes of business operations and support.	N/A
Commercial information, such as information regarding in-game purchase events and value of purchases.	Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners. Affiliates for purposes of business operations and support.	N/A
Demographic information, such as your gender, age, date of birth, and language. Visual information, such as your profile picture and the profile pictures of your friends or contacts.	Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use).Affiliates for purposes of business operations and support. Service providers that enable image functionality on our behalf. Affiliates for purposes of business operations and support. Other players, depending on your sharing preferences.	N/A
Visual information, such as your profile picture and the profile pictures of your friends or contacts.	Service providers that enable image functionality on our behalf. Affiliates for purposes of business operations and support. Other players, depending on your sharing preferences.	N/A
Non-precise geolocation information.	Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use) and payment processors. Affiliates for purposes of business operations and support.	N/A
Other information you may share if you use social features when accessing our Services, including the organizations, links, and other information included on your social profile page.	Service providers, and other providers or partners that support our operational business purposes. Affiliates for purposes of business operations and support. Other players, depending on your sharing preferences.	N/A
Inferences derived from personal information listed above in this chart, such as your characteristics and preferences.	Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use) and payment processors. Affiliates for purposes of business operations and support.	Analytics providers.

Note that we do not have any knowledge of sales or sharing of personal information of minors (e.g., for the purpose of this section, under 16 years of age in California). While our Services may allow you to create an account, we do not otherwise use or disclose any sensitive personal information.

Your Privacy Rights Under Applicable State Law

Subject to applicable law, if you are a resident of California, Virginia, Connecticut, Utah, or Colorado, you may have the following rights:

To Know and Access: to obtain a copy of the specific pieces of personal information we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)

Deletion: to request that Global Worldwide delete your personal information. This right may be limited to the extent that Global Worldwide is permitted or required by applicable law to retain information. (Note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and that if you share devices with someone else who uses the Services, that person may lose game progress or related Account information and access. If you decide to use or access the Services again, Global Worldwide may consider this a new Account, and may collect personal information associated with that Account in accordance with this Privacy Policy.)

Opt-Out of "Sale" and Certain Sharing Practices: depending on the site you are visiting or the app you are visiting and your relationship with us, you have the right to opt-out of certain information sharing practices with Third Parties who do not act as our Service Providers. In some states, like California, this information sharing may qualify as a “share” or a “sale,” while in other states, like Virginia, this information sharing may qualify as “targeted advertising” (collectively, “personalized advertising”). If you wish to opt-out of personalized advertising associated with our games, please visit the “Do Not Sell or Share My Personal Information” setting found in a game’s settings menu, or by contacting us as set forth below.

Correction: to request the correction of inaccurate personal information that we may have on file about you.

Obtain additional details regarding Global Worldwide’s information practices: You may have the right to request disclosures regarding Global Worldwide’s information practices. (Note that this information is generally available in this Privacy Policy).

If you wish to exercise any of the rights described above, email privacy@globalworldwide.com. We will not discriminate against you, in terms of price or services that we offer, if you submit any of the requests listed above.

Verification and Appeal Process: We are required by law to take reasonable steps to verify your identity prior to responding to your request. Please note that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). Please do not delete our game until your request is fulfilled. If we are unable to process your request via our in-game help ticket system, we may verify your request by asking for information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us or with one of our games. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and as permitted by applicable law. Where required by applicable law, we will notify you if we reject your request, and notify you of the reasons we are unable to honor your request.

If you are a resident of Colorado, Virginia, or Connecticut, you have the right to appeal a request we deny when we have verified your identity and still decline to honor your request. The process for that appeal will be sent to you separately if your request is denied.

Authorized Agent: Californian players may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a Californian player to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the player, and have sufficient access to that player’s laptop, desktop, or mobile device to exercise that player’s right digitally. If you are an authorized agent trying to exercise rights on behalf of a Global Worldwide player, then you can make a request on the player’s behalf by contacting us as set forth below in the “Contact Us” section with supporting verification information with proof that you have access to the player’s interface (including, for certain requests, written permission from the player) and proof of your own identity.

XIII. Updates to Our Privacy Policy

From time to time, we may update this Privacy Policy to maintain our commitment to privacy. Updates apply going forward, and never retroactively. When we make changes, we will update the date at the top of this page and make reasonable efforts to notify you if the changes are material. We encourage you to visit this page frequently to keep current with any changes.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@globalworldwide.com.

XV. Contact Us

If you have any questions regarding this Privacy Policy or wish to contact our Data Protection Officer, you may email us at privacy@globalworldwide.com.