Effective Date: May 25, 2018

Privacy Policy

Jam City, Inc., the registered office of which is at 3525 Eastham Drive, Culver City, CA 90232, USA
(“Jam City”, or “we”) provides this Privacy Policy to inform you of our policies and procedures
regarding the collection, use and disclosure of Personal Data we receive from users of our games
and other services we provide (collectively, the “Service”) and as well as from users of any of our
applications, whether on third party websites or as an application for mobile devices (collectively,
the “Application”). The terms “Personal Data” and “Processing” have the meaning set out in Art. 4
of the European General Data Protection Regulation (“GDPR”). The term “Services”, as used in
this Privacy Policy, includes both the Service and the Application. This Privacy Policy applies only
to Personal Data that you provide to us (or permit third party sites to provide us) or that we collect
through the Services. This Privacy Policy may be updated from time to time. We will notify you of
any material changes by posting the new Privacy Policy on the primary access points to the
Services. You are advised to consult this policy regularly for any changes.

Relevant Personal Data

In the course of using the Services, you may provide us with Personal Data either directly or we
may receive it indirectly (from others).

Access data:
When you register through the Services as a registered user or when you choose to create your
own profile we may collect the following Personal Data from you directly:

● Your name;
● Email address;
● Birthday;
● Gender;
● Zip code/Postal Code;
● Username
● Device ID

We also may receive Personal Data related to you from others if you sign-up to use the Services
directly via the Service or Application or via certain third party social networking sites (each, a
Social Networking Service”). In this case, we may extract Personal Data you have provided to
such Social Networking Service (information you make available via the Social Networking Service)
from the account you have with such Social Networking Service and use that Personal Data to
create your Jam City account. In this regard, we may extract the following Personal Data:

● Your name;
● Email address;
● Birthday;
● Gender;
● Zip code/Postal Code;
● Username
● Device ID
● Facebook ID

The Personal Data we extract may depend on the privacy settings you have with the respective
Social Networking Service.
The legal basis for the processing is Art. 6 (1) (f) of the GDPR (legitimate interest) as the provision
of this Personal Data is necessary for us to perform the contract with you. If you do not provide us
the relevant Personal Data you may not be able to use our Services completely.

Data we receive indirectly:

We also may extract the following Personal Data when you are using the Services or are
navigating to the Services from other (third party) websites:

● individual preferences;

● certain information about your computer or mobile device: operating system, software
version and unique advertising identifier;

The legal basis for the processing is Art. 6 (1) (f) of the GDPR (legitimate interest) as we wish to
improve our Services permanently and therefore need to analyse our users’ preferences and
technical background.

Purchase data:

If you choose to purchase any virtual goods as part of your use of the Services, to the extent
available, we or our third party service providers may collect the following Personal Data from you
in order to facilitate your payment for such virtual goods:

● Purchase history (does NOT include payment method details or banking information)

The legal basis for the processing is Art. 6 (1) (b) of the GDPR (performance of a contract) as the
provision of this Personal Data is necessary for us to perform our contract with you. If you do not
provide us the relevant Personal Data you may not be able to use our Services completely.

Log Data:

When you use the Services, whether as a registered user or a non-registered user (any of these, a
Jam City User”), for example in accessing our Services through a Social Networking Service, our
servers automatically record data that your browser sends whenever you visit a website (“Log
Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”)
address, browser type or the webpage you were visiting before you came to the Service, pages of
the websites involved in the Service that you visit, the time spent on those pages, information you
search for, access times and dates, and other statistics.
The legal basis for the processing is Art. 6 (1) (f) of the GDPR (legitimate interest) as we wish to
improve our Services permanently and therefore need to analyse our users’ preferences and
usage habits.


Like many websites, our Service uses “cookies” to collect data. A cookie is a small data file that we
transfer to your computer’s hard disk for record-keeping purposes. We do not link the data we store
in cookies to any Personal Data you submit while using our Services.
Subject to your prior consent, we may participate in behavioural-based advertising. This means
that a third party may place a cookie on your browser, or use a web beacon, to collect data about
your use of our website so that they can provide advertising about products and services tailored to
your interest (“Tracking Cookies”). That advertising may appear either on our Service, or on other
websites. We may ask you to consent to our use of such Tracking Cookies before we start using
them. If you consented to the use of Tracking Cookies in the beginning, you can, at any time,
instruct your browser, by changing its options, to stop accepting cookies or to prompt you before
accepting a cookie from the websites you visit. On mobile you can reset your settings by taking the

following steps (for iOS: https://support.apple.com/en-us/HT202074 and for Android:
https://support.google.com/ads/answer/2662922?hl=en). If you do not accept cookies, however,
you may not be able to use all portions of the website or all functionality of our Services.
The legal basis for the processing is Art. 6 (1) (a) of the GDPR (consent).
Some web browsers and devices permit you to broadcast a preference that you not be “tracked”
online. At this time we do not modify your experience based upon whether such a signal is
We do not use any automated decision-making, including profiling.

Purpose of the Processing

Access data, data we receive indirectly and purchase data:

We use your Personal Data (access data, data we receive indirectly and purchase data as listed
above) to provide our Services to you and administer your inquiries. Subject to your prior consent,
we also use your Personal Data to contact you with newsletters, marketing or promotional
materials and other information that may be of interest to you. If you decide at any time that you no
longer wish to receive such communications from us, please follow the unsubscribe instructions
provided in any of the communications or update your “user preferences” section in your profile
webpage. (See “Changing or Deleting Information” below.)

Log Data:

We use the Log Data to monitor and analyze your use of the Services and for the Service’s
technical administration, to increase the functionality and user-friendliness of our Services, and to
better tailor the Services to our visitors’ needs. For example, some of this Log Data is collected so
that when you use our Services again, it will recognize you and serve advertisements and other
information appropriate to your interests. We also use this Log Data to verify that visitors to the
Service meet the criteria required to process their requests. We do not treat Log Data as Personal
Data or use it in association with other Personal Data, though we may aggregate, analyze and
evaluate such Log Data for the same purposes as stated above regarding other Non-Identifying


We use cookies for two purposes. First, we utilize persistent cookies to save your registration ID
and login password for future logins. Second, we utilize session ID cookies to enable certain
features of the Services in order to better understand how you interact with the Services and to
monitor aggregate usage by Jam City Users and web traffic routing. Unlike persistent cookies,
session cookies are deleted from your computer when you log off from the Services and then close
your browser. We use Tracking Cookies to be able to address you with advertisements matching
your interest.

Data Sharing and Disclosure

Jam City Registered Users:

If you register through the Services on the Service and submit your Personal Data to create a
profile webpage, other registered users will see your “User Name” (“Subscriber Identifier”). You can
choose what other Personal Data you provide as part of your profile (“Other Subscriber
Information”) and in some cases you can choose whether to share that information publicly
through the Services by making selections via the “user preferences” section of your profile
webpage. Providing Other Subscriber Information is voluntary and should correlate with the degree
of interaction you want to have with other Jam City Users. We recommend that you guard your
anonymity and sensitive Personal Data and that you not use your real name as your “User Name,”
since that would allow others to identify you.
In particular, we may decide to share IDFA, IDFV, IP address and aggregated information with
advertisers. Such information may be used to send you advertisements for products and services
that are relevant to your interests if you have consented to such practice.
For example, we may share the advertising identifier associated with your device (such as the
Apple IDFA and Android Advertising ID) with advertisers. An advertising identifier is an
alphanumeric string that can be used to identify your device so that advertisers can serve relevant
ads to you. We use the Apple IDFA only as permitted by Apple, and we use the Android
Advertising ID only as permitted by Google. An advertising identifier is assigned, and ad tracking is
turned on, by default on your mobile device. You may limit the use of or reset your advertising
device ID using the privacy settings on your mobile device; in some cases you may need to reset
the operating system to reset the advertising device ID. We do not associate any of your Personal

Data with your advertising device ID without your consent (which may be given by you in our terms
of use for an Application).

Service Providers:

We may employ third party companies and individuals to facilitate our services, to provide our
Services on our behalf, to perform services related to our Services (e.g., without limitation,
maintenance services, database management, web analytics and improvement of the website
features) or to assist us in analyzing how our Services are used. These third parties have access to
your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or
use it for any other purpose.

Social Networking Sites:

We may share the information in your Jam City account profile (including your Personal Data) with
the Social Networking Sites you have linked to your Jam City account to provide you with
enhanced services. These third parties have access to your Personal Data only for this purpose
(unless they legitimately have received your Personal Data independently of the Jam City service)
and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement:

Jam City cooperates with government and law enforcement officials and private parties to enforce
and comply with the law. We will disclose any Personal Data about you to government or law
enforcement officials if required by law.

Business Transfers:

Jam City may sell, transfer or otherwise share some or all of its assets, including your Personal
Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of

Your Rights

As a Jam City User you have the rights explained in this section in accordance with Art. 12 to 23
GDPR. If you want to exercise any of your rights or receive further explanation about them please
contact us via the contact details at the bottom of this Privacy Policy. Please note that some of

these rights may be connected to certain statutory preconditions and thus, might not be applicable
to you and your specific situation.

● Right of access
You have the right to gain access to the Personal Data that we process about you. Should you
have any questions regarding the processing, or would you like to have more insight in the
Personal Data about you that we process, you are always welcome to contact us and we
will provide you with further information.

● Right to rectification
You can request from us to correct information inaccurately stored by us without undue delay. You
also have the right to have incomplete personal data completed, including by means of
providing a supplementary statement.

● Right to erasure / right to be forgotten
You have the right to request from us to permanently delete your Personal Data. You can make
such a request if you for example believe that the Personal Data are no longer necessary
in relation to the purpose for which the Personal Data were collected or otherwise

● Right to restrict the processing activities
You have the right to restrict our processing activities. If you choose to restrict our processing
activities as regards to the Services, you might not be able to use them.

● Right to data portability
You have the right to request from us that we send your Personal Data in a structured, commonly
used and machine-readable format, and to transmit those data to another controller.

● Right to Object
You have the right to object to our processing of your Personal Data. If you choose to object to our
processing activities, you might not be able to use all of our Services.

● Right to lodge a complaint with a supervisory authority
If you are unsatisfied with the way we treat your Personal Data you may reach out to us at
all times to solve the issue. However, you always have the right to lodge a complaint with a
supervisory authority.

● Right to Withdraw Consent
You have the right to withdraw consent at any time. The withdrawal of your consent will not
affect the lawfulness of the processing based on consent before its withdrawal.

If you would like to exercise any of the rights listed above, please open a customer support ticket
by clicking on the link below:



Jam City is concerned with safeguarding your Personal Data.
Taking into account the state of the art, the costs of implementation and the nature, scope, context
and purposes of processing as well as the risk of varying likelihood and severity for the rights and
freedoms of natural persons, we have implemented appropriate technical and organizational
measures to ensure a level of security appropriate to the risk in accordance with Art. 32 of the

Personal Data Breach

We will make any legally required disclosures of any Personal Data Breach (as defined in Art. 4 no
12 of the GDPR) to you via email, mail, telephone, or conspicuous posting on our website in the
most expedient time possible and without unreasonable delay, insofar as consistent with (i) the
legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the
breach and restore the reasonable integrity of the data system. We reserve the right to choose
which method we use to contact you about such an event.

International Transfer

Your information may be transferred to — and maintained on — computers located outside of your
state, province, country or other governmental jurisdiction where the privacy laws may not be as
protective as those in your jurisdiction. If you are located outside the United States and choose to
provide Personal Data to us, Jam City transfers Personal Data to the United States and processes

it there. For such cases we will contractually ensure that the protection level regarding your
Personal Data is the same as ours (“safeguards”).

Retention Period

We will store your Personal Data for the time necessary to perform our Services to you.

Our Policy Towards Children

These Services are not directed to children under 13. We do not knowingly collect Personal Data
from children under 13. If a parent or guardian becomes aware that his or her child has provided us
with Personal Data without their consent, he or she should contact us at privacy@jamcity.com. If
we become aware that a child under 13 has provided us with Personal Data, we will delete such
information from our files.


Identity theft and the practice currently known as “phishing” are of great concern to Jam City.
Safeguarding information to help protect you from identity theft is a top priority. We do not and will
not, at any time, request your credit card information, your account ID, login password, or national
identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more
information about phishing, visit the Federal Trade Commission’s website.

Links to Other Sites

Our Services may provide links to other websites. If you choose to visit an advertiser by “clicking
on” a banner ad or other type of advertisement, or click on another third party link, you will be
directed to that third party’s website. The fact that we link to a website or present a banner ad or
other type of advertisement is not an endorsement, authorization or representation of our affiliation
with that third party, nor is it an endorsement of their privacy or information security policies or
practices. We do not exercise control over third party websites. These other websites may place
their own cookies or other files on your computer, collect or solicit Personal Data from you. Other
websites follow different rules regarding the use or disclosure of the Personal Data you submit to
them. We encourage you to read the privacy policies or statements of the other websites you visit.

However, we will ensure contractually that everyone we share your Personal Data with provides for
sufficient security measures.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@jamcity.com and
Address: Jam City, Inc., 3525 Eastham Drive, Culver City, CA 90232, USA
EU representative: Rivacy GmbH, Hammerbrookstr. 90, 20097 Hamburg info@rivacy.eu
Our DPO’s contact details: dpo@jamcity.com





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3562 Eastham Drive Culver City, CA 90232