California Privacy Notice

FOR CALIFORNIA RESIDENTS ONLY

This Privacy Notice is effective as of January 1, 2020 and applies to residents of the State of California only.

PLAYSTUDIOS, Inc. and our affiliates, PLAYSTUDIOS Asia Limited, and PLAYSTUDIOS International Israel Ltd. (“PLAYSTUDIOS”,” “we,” “us” or “our”) value your privacy. We offer a variety of games through various means, including our mobile applications and our Facebook application (collectively, our “Applications”). On our website www.PlayStudios.com (the “Site”), we provide information about our products and services, including those games, and how you may redeem Loyalty Points that you accumulate through the Applications. In this Privacy Notice (“Notice”), we describe how we collect, use, and disclose information that we obtain about visitors to our Site and our Applications, and the services offered on each (collectively, “Services”).

Your use of our Site, Applications or Services, and any dispute over privacy, is subject to this Notice, including its applicable limitations on damages and the resolution of disputes.

The PLAYSTUDIOS Terms of Services also apply to your use of our Applications, and can be found here: www.playstudios.com/#/terms

California consumers have certain rights regarding their personal information that are provided under the “California Consumer Privacy Act” or the “CCPA”.

If you are a California consumer, you have the right to make requests about and receive disclosures of personal information that we collect about you. Generally, there are four types of requests that you can make to exercise these rights: (i) Request to Know, (ii) Request to Delete, (ii) Request to Opt-Out, and (iv) Request to Opt In.

• (i) Request to Know. You can request that we disclose to you categories of personal information we collect about you and disclose for a business purpose, the business or commercial purposes for collecting that information, the sources of the information, the business or commercial purpose for collecting or selling it or for disclosing it for a business purpose, the categories of third parties we share it with, and the specific pieces of personal information we have collected over the prior 12-month period.
• (ii) Request to Delete. You can request that we delete your personal information.
• (iii) Request to Opt-Out. If we sell your personal information, you have the right to opt out of such sale.
• (iv) Request to Opt In. If you exercised your right to opt out of a sale of your personal information, you could subsequently request to opt in, or, we could ask you to opt in so long as it has been at least 12 months since you opted out.

Am I a “consumer” under the CCPA?

Under the CPPA, “consumer” means the same thing as “resident” under Section 17014 of Title 18 of the California Code of Regulations, as that section read on September 2, 2017, however identified, including by any unique identifier. Under that particular section, a “resident” includes (i) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State who is outside the State for a temporary or transitory purpose.

What is “personal information” under the CCPA?

Under the CCPA, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

We don’t sell your personal information.

Under the CCPA, “sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.

As of the date of this Privacy Notice, we do not sell your personal information

In-App Advertising.

We offer third-party mobile ads in our Applications. However, you are not required to view any of these ads. If you do elect to view or otherwise interact with an ad, the ad will be provided by a third-party ad service and the ad mediation service and the ultimate third-party delivering the ad will have access to your DeviceAdId and IP Address, as well as device-specific information such as device name and device operating system. By interacting with an ad you are consenting to the transfer of this information to the ad mediation service provider and the third-party company delivering the ad.

How to make a request under the CCPA.

To make a Request to Know or Request to Delete, please click here, or send your request by mail to:
PLAYSTUDIOS, Inc.
Attn: Privacy Department
10300 W. Charleston Blvd, Suite 13272
Las Vegas, NV 89135

How to designate an authorized agent to make a request on your behalf.

You can designate an agent to make a request on your behalf by submitting a copy of a notarized authorization that identifies the agent and you, and includes proof of residency in the State of California, and mailing it to:
PLAYSTUDIOS, Inc.
Attn: Privacy Department
10300 W. Charleston Blvd, Suite 13272
Las Vegas, NV 89135

What happens if you submit a Request to Know or a Request to Delete?

If you submit a Request to Know or a Request to Delete, we will ask for you to provide certain information so that we can verify that you are a California consumer, and to verify who you are (e.g. evidence of your California residency, your support codes, games you have recently played, your player level, etc.). Once we receive and confirm the verification information we will proceed with your request.

For a Request to Delete, we delete or deidentify your personal information such that you cannot be identified from the information that we retain.

Please know, however, that if you make a Request to Delete and subsequently download and play any of our Applications, none of your historical performance data will be available, meaning you will lose any virtual currency, game progress, and Loyalty Points that you had at the time your request is processed.

However, we can retain personal information for any of the following reasons:

• To complete a transaction (e.g. redemption of an award).
• To provide a good or service requested by you.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest.
• For internal reasonable uses that are based on your use of our Applications.
• To comply with a legal obligation.
• To otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

We are prohibited from discriminating against any consumer that exercises their rights under the CCPA.

Under the CCPA, we are prohibited from discriminating against a consumer because the consumer exercised any of the consumer’s rights under the CCPA, including, but not limited to, by:

1. Denying goods or services to the consumer.
2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
3. Providing a different level or quality of goods or services to the consumer, if the consumer exercises the consumer’s rights under this title.
4. Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services unless

The CCPA does not prohibit us from charging a consumer a different price or rate, or from providing a different level or quality of goods or services to the consumer, if that difference is reasonably related to the value provided to the consumer by the consumer’s data. We do not currently charge anything for playing our Applications.
Under the CCPA, we are permitted to offer financial incentives, including payments to consumers as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information. We are also permitted to offer a different price, rate, level, or quality of goods or services to the consumer if that price or difference is directly related to the value provided by the consumer’s data.
We do not currently offer financial incentives or different prices, rates, levels or quality of goods or services that are directly related to the value of consumer’s data.

What Information Do We Collect About You and Why?

We collect data about your play activity on our Applications, including what games you play, your spins, game play outcomes, your use of virtual chips, game progress, quest progress, and participation in special events or offers.
What information we collect when you play our Applications depends on whether or not you play on Facebook, or if you connect your use of the Application on your mobile device to Facebook. Certain areas and features of the Applications require a connection to Facebook, such as to accumulate and redeem Loyalty Points, Virtual Items and Awards, and to post any User Content. If you play via Facebook, or you connect the Application on your mobile device to Facebook, we will keep track of your Loyalty Points. If you do not connect the Application on your mobile device to Facebook, your progress in the Application, including level, XP and Loyalty Points could be lost, and you will not be able to use your Loyalty Points for Awards.

Information We Collect About You as a Guest Player

You may play our Applications on your mobile device without connecting to a Facebook account. If you play this way, you are playing as a “Guest”. As a Guest player, we will collect the following information from your mobile device: IPAddress, DeviceAdId, DeviceModel, DeviceName, OperatingSystem, SystemMemorySize, Operating System Name, Operating System Version, and Country. We will also create a Support Code and Player ID that we associate with your device.

Information We Collect About You From Facebook.

When you log into our mobile application through your Facebook account, you will be asked to enter your Facebook email address and password. Facebook controls the information collected from you during the log-in process; PLAYSTUDIOS does not control the information that Facebook collects from you. When you use any of our Applications through Facebook or on a mobile Application that you have connected to Facebook, we will have access to, and may collect and store, the following information: your Facebook ID, first and last name, link to your profile picture, gender, friends, locale and time zone, third-party ID, date of birth, email address, and IP address. We will also have access to any other information you have set to public on your Facebook account. We may use this information to

• send you email;
• post to your Wall;
• access posts in your news feed;
• publicly identify your avatar while you are playing in our game (i.e. your avatar, first initial, last name, country or state listed in your Facebook profile, player level, and largest win will be visible to other players);
• publish on our social media sites your participation in an event or contest, e.g. as a winner; and
• access your Facebook data at any time even if you are not using Facebook.

Please note, if you allow PLAYSTUDIOS to have access to this information, then PLAYSTUDIOS will have access to this information even if you have chosen not to make that information public.

For information about how Facebook may disclose your information, including any information you make public, please consult the Facebook Privacy Notice. We have no control over how Facebook uses or discloses the personal information you provide to it. We store the information that we receive from Facebook along with other information that we collect from you or receive about you.

Information We Collect About You From Awards Redemptions

We facilitate the redemption of awards through a proprietary platform called playAWARDS. Some of our awards partners connect directly with the playAWARDS platform so that, with your consent, we can transfer information about you to the awards partner as part of your awards redemption process. Some of our awards partners require that you provide information about yourself so that they can complete the award redemption, cross-check that information against information that they have to avoid creating duplicate accounts for you, and ensure that you comply with the terms of the award. By providing any information about yourself as part of the awards redemption process, you are consenting to (i) our collection of that information, and (ii) our transfer of that information to the awards partner. The awards partner’s use of that information is subject to the privacy notice and terms provided by the awards partner. We store the information that we receive from you as part of the awards redemption process along with other information that we collect from you or receive about you.

Information We Collect About You From Support Requests

If you submit a request to us through the Support tab in the game, or via Facebook, that request is sent to us via email through our third-party customer service provider. When we receive your request, we save the email and the correspondence between you and us. We might request that you provide us with information about your gameplay or the issue you are contacting us about in order to better provide you with a response or a solution to an issue you are experiencing. We store those emails on our system and a copy is retained by our third-party customer service provider.

Information We Collect About You as a VIP or Hosted Player

If you become a hosted player, or VIP player, we might engage with you directly via in-app communications, email, and sometimes, with your consent, via phone. Based on our communications with you we will gather and store personal information about you that you provide to us.

Information We Collect Automatically; Cookies and Other Tracking Technologies.

We use cookies, including Flash cookies, and other tracking technologies (including technologies designed for mobile devices) to track information about your use of our Services. We automatically collect the following information about you from your use of our Services through these technologies: your browser type and operating system; web pages you view; links you click; your IP address; and the length of time you visit our Site, Applications, and/or use our Services.

For users of our mobile application, in addition to the information listed above, we collect the following: language information, your geo-location (with your permission), unique device identifier (as permitted), device advertising id, device name and model, device operating system, and system memory size.

We may use this information in the aggregate or we may combine it with personal information about you if you connect your use of the Application through Facebook, you become a hosted player and provide us personal information, or you submit a support request in which you provide personal information.

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Applications, while other cookies are used to enable a faster log-in process or to allow us to track your activities at our Site and Applications. There are two types of cookies: session-based and persistent-based cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your computer or mobile device when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
• Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.
• Third Party Cookies. We may also engage third parties to track and analyze non-personally and personally identifiable Site data. We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze Site usage. Such third parties may combine the information that we provide about you with other information that they have collected. This Notice does not cover such third parties’ use of the data.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.

Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. You cannot control, delete, or disable the acceptance of Flash LSOs through your browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash cookies, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel“ and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Information we collect for analytics purposes.

We use automated devices and applications, such as Google Analytics or Facebook Insights, to evaluate usage of our Site and, to the extent permitted, in our Applications. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services and user experiences.

How We Use Your Information.

We use the information that we gather about you for the following purposes:

• To provide our Services to you.
• To communicate with you about your use of our Services.
• To respond to your inquiries.
• To fulfill your orders, facilitate redemption of Awards, and for other customer service purposes.
• To track your play activity and progress in our games.
• To provide personal hosted services to you.
• To track Application crash events.
• To display ads in the Applications.
• To tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using the Site, Applications, or our Services.
• Where permitted by law, and in accordance with Facebook’s applicable terms and conditions, for marketing and promotional purposes. For example, we may use your information, such as your email address, to email you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you.
• To assist in determining where to advertise our Services on third party websites and applications. When we engage an ad service to advertise our games, we submit hashed “suppression lists” so that we aren’t sending ads to players who are already playing our games. The suppression list contains hashed Ad IDs. Hashed data converts a string of characters to data of a fixed length using an algorithm.
• To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services, analyze player traffic and activity, respond to user desires and preferences, and for other research and analytical purposes.
• If you installed one of our Applications because you viewed a mobile ad, we will use information to identify the third-party ad network that displayed the mobile ad for us.
• We also may post to your Facebook Wall, access posts in your news feeds, and access your Facebook data when you are not logged into Facebook. We will use and access this information for the purposes described in this section and as discussed below.
• As required or permitted by law.

Who do We Share Your Information with and Why?

We may share the information that we receive from you, including personal information, as follows:

• Facebook Friends. Your username and profile picture will be visible to all other PLAYSTUDIOS users, regardless of whether they are your Facebook friends. In addition, when you join PLAYSTUDIOS, if you grant request to post on your Wall under settings, a notification will be visible on your Facebook page telling your friends that you have started using PLAYSTUDIOS. The PLAYSTUDIOS Facebook application will also be visible on your Facebook page under “applications.”
• PLAYSTUDIOS Users. Your username and any information that you post to PLAYSTUDIOS, including, without limitation, reviews, comments, scores, participation in the game, and text will be available to, and searchable by, all other PLAYSTUDIOS users.
• Our Partners. We may share certain information regarding your Awards with our partners. The partners will use this information solely for the purpose of determining your eligibility for the Award. Any information that you submit to a third party will be governed by that third party’s website privacy Notice and not this Notice. We do not share your personal information with our partners or other third parties for their direct marketing purposes.
• In-App. We may share your Facebook profile picture, your First Name initial and full Last Name, your country listed on your Facebook profile, your player level and your largest win. This information is available for view by other players who are playing POP! Slots in the same gaming area. It can be viewed by scrolling over your avatar.
• Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. For example:
  • We use Amazon Web Service and the Simple Storage Service (S3) to store information about you and your activities in our applications on databases.
  • We include SDKs within our Applications that transfer game transaction data to third-party service providers who monitor crashes and create error logs so that we can maintain the Applications.
  • We use a third-party service provider to receive support requests and transfer them to us via email.
  • We use third-party service providers to help us with ad attribution. The service provider receives information about how our ads are viewed and interacted with and whether the viewer downloads, installs and interacts with any of our Applications.
  • We use third-party service providers to facilitate running our own ads, as well as third-party mobile ads in our Applications.
• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
• In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena, or to meet national security or law enforcement requirements.
• To Protect PLAYSTUDIOS and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Notice, or as evidence in litigation in which PLAYSTUDIOS is involved.
• Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Third-Party Links.

Our Site and Applications contain links to third-party websites. Any access to and use of such linked websites is not governed by this Notice, but instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

User Generated Content.

We may permit users to submit their own content to our Site and Applications including, without limitation, pictures, reviews, comments and other text. We are not responsible for the privacy of any information that you choose to submit through our Site, Applications and Services, or through any public forum, such as a blog, or for the accuracy of any information contained in those postings. Any information that you disclose becomes public information. We cannot prevent such information from being used in a manner that may violate this Notice, the law, or your personal privacy.

Security of My Information.

We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. To change your Facebook password, you must go to the Facebook site and follow its procedures for changing your password.

What Choices Do I Have Regarding Opting-Out of Promotional or Information Emails?

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

As noted above, to adjust the types of information about you that we receive from Facebook, you must change your Facebook account settings directly through Facebook.

Third-Party Ad Networks.

We may use third parties to assist us in advertising our Site, Applications and Services, and we participate in third-party ad networks that may display advertisements on other websites or mobile applications based on your visits to our Site as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy Notice, not this one. We may provide these third-party advertisers with information about your usage of our Site and our Services, as well as aggregate or non-personal information about visitors to our Site and users of our Service.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices  (DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.

Children Under 13.

Our Services are not designed for persons under 21. We do not knowingly collect information from persons under 18, including children under 13 in particular. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Special Notice to California Consumers.

California residents may request a list of certain third parties to which we have disclosed certain personal information about you for the third-party’s own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response to you. We will respond to you within ten (10) days, and complete your request within forty-five (45) days. You may request this information in writing by contacting us at:

Attn: Privacy Department
PLAYSTUDIOS
10300 W. Charleston Blvd, Suite 13272
Las Vegas, NV 89135
(702) 800-5716
privacy@playstudios.com

Contact Us.

If you have questions about the CCPA-related privacy aspects of our Services please contact us at:

Attn: Privacy Department
PLAYSTUDIOS
10300 W. Charleston Blvd, Suite 13272
Las Vegas, NV 89135

Changes to this Notice.

This Notice is current as of the effective date set forth above. We may change this Notice from time to time, so please be sure to check back periodically. We will post any changes to this Notice on our Site. If we make any changes to this Notice that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

How to Obtain a Copy of this Notice

If you would like a copy of this Privacy Notice, contact us at privacy@playstudios.com and we will send you a copy in pdf format.