Privacy Policy 

(Last updated: January 20th, 2021)

4th Ave and its affiliates (collectively “4th Ave” “we” or “us”) respect the privacy of each and every user on our websites, games, and various related services. This Privacy Policy delineates the type of information that we gather about you, how we might use that information, whether we disclose that information to anyone, and the choices you have regarding that information so that you can be more informed. You acknowledge that this Privacy Policy is part of our Terms of Use. Capitalized terms not otherwise defined herein shall have the same meaning as defined in the Terms of Use (the “Terms”). BY ACCESSING AND USING OUR SERVICES, YOU AGREE TO BE BOUND BY ALL OF THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY.

We may amend any portion of this Privacy Policy at any time in our sole discretion by posting the amended Privacy Policy on 4th Ave branded Website(s) and/or within our Applications. You will be deemed to have accepted such amendments by continuing to use our services and, except as otherwise stated, any such amendments will take effect immediately upon posting said amendments on our website. 

  1. Information We Collect from You. 
    1. To provide the 4th Ave Products we must process information about you. The type of information that we collect depends on how you use our products. This section details what information we are collecting from you. 
    2. Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities while using our Services, such as registering a user account, downloading and installing Application(s), playing Game(s), purchasing Virtual Money or Virtual Goods, sending and/or posting any user Content, entering a sweepstakes or contest, registering or participating in an event or promotion, or sending us feedback, we may ask you to provide certain information about yourself. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information. Such information may include, but is not limited to, your first and last name (the “Real Name”), username (the “User ID”), mailing address, e-mail address, telephone number, credit card, crypto wallet or other online Identifiers. We only collect your personal information after obtaining your consent to collect personal information. Collection of personal information occurs when you register your personal information by typing it into the appropriate text fields and consent to the collection. You have the right to refuse or withdraw your personal information; however, it may interfere with your ability to use the Services.
    3. Usage Information: We collect details of your use of our Services and the resources that you access. Such usage information may include information about how and when you access or use our Services (such as Games accessed, game score, pages visited, purchase and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your game play). 
    4. Interaction and Communications among Users: We collect information about (i) your interaction with other users (for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and (ii) your communication and interaction with your contacts through social media channels (including, social network services, messengers, chats and any other services which has social features like invite friends and sharing information with friends)
    5. Technical Information: We collect general technical data pertaining to you (such as information about the device you use to access our Services, IP address, telephone number assigned and associated with your device, operating system, browser type, device identifier, advertising ID, locale, and other system information). 
    6. User Communication with 4th Avenue. If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence. 
    7. Public Posting/ Shared Content: Some of our Games allow users to post, share, communicate with, or otherwise transmit content publicly, such as by participating in player forums, message boards, news feeds, status updates, sending messages or invitations to other users, chatting with other users, and/or posting photos (collectively the “Public Postings”). We may collect and store archives of such Public Postings on 4th Ave servers, and all Public Postings are subject to this Privacy Policy. Such Public Posting or shared content will be visible to anyone who has access to our Services and may also be viewable outside of our Websites or Services. You should exercise caution in all public postings, as it may result in the disclosure of private information, for which we are not responsible.
    8. Customer Support Correspondence: When you contact our customer support team for assistance, we may ask for your name and contact information and any other information needed or relevant to assist you with your inquiry, including without limitation any transaction and payment information. 
    9. Cookies: We collect technical information and usage data, which may be linked and identified with your account, by using cookies and other tracking technologies. We may use cookies to store certain types of information each time you use our Services. To find out more about how we use cookies, please review the additional information in this Privacy Policy under the Section entitled “Use of Cookies or Other Tracking Technologies?”
  2. Data collected from third parties. 
    1. Information We Collect from Third Parties:  We receive information about you from third parties (i) when you purchase our games or download Application from another party, such as Google Play or the Apple App store, (ii) when you play our games using a third-party device, such as a game console, or (iii) when you choose to sign into our Website or Application using a third-party social network account (such as Facebook, Game Center, Twitter, etc).  The information we receive from such third parties may include your name, username, photographs, and other biographic information, and device identifier, any network service account number assigned by such third party, and Game usage data.  You should review the terms of service and privacy policies of such third parties and understand how they treat your data and what data they might share with us.
    2. Friends Matching:  With your consent, we may periodically access your contacts and friends list on your social network account(s) that you use to sign into our Website or Application.  We will use your contacts’ information to help you find your friends and play our Games socially with them.
    3. Payment: When you purchase our products or services through third party platforms (such as Apple App Store, Google Play Store, Amazon Kindle, or your Crypto wallet), you will be required to provide certain payment and billing information directly to such third-party platforms, and we do not collect or store any payment information from you. Our Services allow you to link a Crypto Wallet to your Account, however, we do not store or keep any of your financial information on our servers. 
  3. Use of the Information We Collect. 
    1. 4th Ave uses information collected from you for many different purposes. We primarily use the information in order to provide you our Services and information about our Services. However, we may also use the information we collect for such other purposes as are generally allowed by law. As allowed by law, we may use your personal information, including Personal Identifying Information, for such purposes, including without limitation: 
      1. contacting you as a part of customer service, to sending you updates about our Services, etc;
      2. managing your account and improving your experience when you use our Services; 
      3. researching or surveying related to our Services and asking you to participate in such research or surveys relating to our Services; 
      4. marketing and promotion of our Services or related products, including those of a third party’s products which are related to our Services (If you do not want us to use your data in this way, please let us know by contacting us through Customer Center found within our Website or Applications); 
      5. sending you offers, promotions, information, newsletters, and communication regarding our Services or products and merchandises relating to our Services;
      6. creating reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services;
      7. vii.delivering relevant advertising to you and measuring and analyzing effectiveness of advertising, including advertising of third parties placed within the Services;
      8. viii.monitoring the Services, including the Website, Games, Applications, and networks, and operation thereof;
      9. resolving disputes or issues;
      10. tracking purchases and usage information; 
      11. preventing cheating, crime, and/or fraud;
      12. xii.administering sweepstakes and contests; 
      13. xiii.enforcing the legal terms governing your use of our Services; and 
      14. xiv.any other purpose as we determine, in our sole discretion, to be necessary or required to ensure the safety and/or the integrity of our users, employees, third parties, public, and/or our Services, or to comply with requirements of any applicable law. 
  4. Use of Cookies or other Tracking Technologies. 
    1. We use cookies and similar technologies to facilitate and customize your use of our Services. A cookie is a small data file, which we store on your computer or mobile device that can later be retrieved to identify you to us. USE OF OUR SERVICE SHALL BE CONSIDRED CONSENT TO THESE COOKIES AND OTHER SIMILAR TECHNOLOGIES. We may use cookies and similar technologies, among other things, to:
      1. allow us to recognize you and your device;
      2. allow our Services to interact with a third-party social network or platform (where you have chosen to allow such interaction);
      3. allow our payment processors to process your payment instructions;
      4. provide you with more customized Services, for example, to provide our services in your preferred language; or
      5. obtain data which will allow us to understand how people are using our Services so that we can improve them. 
    2. You may always change your browser setting (for Website use) or contact our division of data protection at email to disable, limit, delete, or otherwise manage cookies. Disabling or limiting cookies may cause some parts of our Services not to work as intended and some features may not be available entirely. We currently do not recognize or respond to “Do Not Track” signals. By accessing our Websites or using our Services you consent to our use of cookies in accordance with this Privacy Policy. You can disable cookies through your web or phone browser settings but you may find you are not able to enjoy all the features of our Services if you do so.
  5. With Whom your Information May be Shared. 
    1. We do provide some of our Services through contractual arrangement with affiliates, services providers, and other third parties (collectively, “Service Providers”). We will share your personal information with our Service Providers for all purposes described in Section 3 of this Privacy Policy entitled “Use of the Information We Collect” and as reasonably necessary in order to provide the Services to you or to carry out your instruction (for example, to process a payment instruction).  When our Service Providers collect or receive personal information, we require them to use such information only on our behalf and for purposes consistent with this Privacy Policy.
    2. We may also share your personal information when we determine that it is reasonably necessary (i) to comply with any legal obligation, (ii) to enforce or apply our terms and conditions and/or any other agreement with you; or (iii) to protect the rights, property, or safety of us, our users, or others; or (iv) for other purposes as we reasonably believe are permitted by law or regulation.
    3. Sharing of Non-Personally Identifiable Information: We may also provide non-personally identifiable information about users (where your data is on an anonymous and aggregated basis) to third party companies, including but not limited to third party advertisers, consultants, service providers and our affiliates. Such data will not include any information by which you could be personally identified.
    4. Social Features: When you use the social features of our Services, we share information about you, including your name, user ID, social media profile, picture, game scores and progress, and any other information that you submit or post using such social features.  For example, other players may see your name, picture, profile information, and your scores and game progress.  In addition, information or message that you submit or post through message boards, forums and/or chat areas will be published on our Websites, Applications, and/or third-party social media networks that you sign into. Third-party social media features and tools integrated into our Services (such as the Facebook “Like” button or “Share” button) are hosted by a third party, who may also collect information when you use our Services. These third-party features and tools are subject to the privacy policy of the third party that provides it.
    5. Mobile Advertising. Our Mobile Games include advertising for third party products and services. By accepting this Privacy Policy and downloading or continuing to play our mobile games, and unless you opt out of interest-based advertising, you consent to us and our advertising partners collecting, sharing, and using information about you to show you relevant third-party ads that might interest you in our mobile games, and to improve advertising, targeting, and measurement systems. 
    6. Business Transfer: In a business transaction, such as a merger, acquisition, dissolution (including bankruptcy), change of control, or a sale of all or a portion of our assets, customer information, including personally identifiable information, generally is one of the transferred business assets. In the event that 4th Ave undergoes such transactions, including preparation of any of such transactions, we may share, disclose or transfer all of your information, including personal information, to the successor. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy. We will not sell or rent your information to any third party outside of these circumstances.
    7. Compliance with Legal Obligations: Occasionally we may be required by law to disclose personally identifiable information. For example, we disclose such information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful. 
  6. Information Storage and Security. 
    1. 4th Ave understands the importance of personal information and data, and the security of that data is of even more import. We maintain appropriate technical and physical safeguards to protect your personal information and data against unauthorized access, loss, and misuse. We take commercially reasonable security measures to protect your personal information and data, including encryption of sensitive information (such as payment information) using Secure encryption algorithms and the use of firewalls and an intrusion detection system (IDS). 
    2. Despite our best efforts to protect your personal information and data, no security system or measure is impenetrable. As such, we cannot guarantee the security of your information. You hereby acknowledge and agree to use our Services at your own risk. We do not assume any responsibility for the unauthorized use of or access to your information under out control. 
    3. Information Storage. Your personal information may be transferred to, and stored at, a destination outside of your country or jurisdiction, including but not limited to our data center in the State of Pennsylvania, USA.  It may also be processed by personnel of our affiliates and third-party service provider who may operate outside of your country or jurisdiction. In such case, we will take reasonable steps to require such third party in possession of your personal information to take commercially reasonable security measures to protect the information. On the other hand, the data and privacy protection laws of other countries may not be as comprehensive as those laws in your country of residence.  By using our Services, you consent to your personal information being transferred to recipients in other countries and being stored and processed in the servers located in other countries.
  7. How to Review, Correct, or Delete your Personal Identifying Information. 
    1. You can request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please submit your request in writing at Email. 
    2. We want to ensure that your personal information is accurate and up to date. You may ask us to correct or remove your personal information by contacting us at Email. You may also update your account information by logging into your account. 
    3. You may request to delete your account by logging in to the account that you wish to delete and going to the Customer Support menu to submit your request.  We may ask you for certain personal information to confirm your identity before processing your request.  Please note that before we process your deletion request, we will ask you to verify your account information or log into the account you wish to delete to confirm your identity a second time. In addition, if you have multiple Game profiles, you’ll need to make separate requests for each Game profile that you wish to close.
    4. Please be aware that we may not be able to delete your information in some cases.  For example, we cannot correct or delete any information that you have shared on any third-party social network or platform.  Likewise, any information that you have publicly shared through our Services may be copied by a third party whom we do not control, and we may not be able to remove such information. In addition, any information that is saved in aggregate form or that cannot, in our sole discretion, be removed without undue burden to us may not be deleted. Moreover, we may not be able to delete your information if retention of your information is necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and exercise or defend against a legal claim.  Such information may be disclosed pursuant to this Privacy Policy regardless of whether you have terminated your account or deleted your information.
    5. Any third-party platform that you use to access the Services may also retain backup copies of your information even after your account is deleted or terminated and may use them subject to their policies. If you are a resident of California or an EU resident, you can find your privacy rights under “13. California Privacy Rights” or “14. EU Data Protection Rights.”
  8. Your Choices Regarding Collection, Use, and Distribution of your Information. 
    1. You have the right to ask us not to use your personal information for marketing purposes. To change your marketing preferences, or to unsubscribe, please contact us at Email. 
    2. You have choices with respect to cookies. By modifying your browser preferences, you can choose to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our Services may not work properly.
    3. You can also make changes to what data a third-party social network or platform shares with us, or stop our Services interacting with that social network or platform by adjusting your settings with that third-party provider; however, you may not be able to enjoy some social features of our Services. 
  9. Information about Privacy Policies and Data Collection at any Third-Party Sites Accessible from Our Services. 
    1. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. You hereby Acknowledge and agree that 4th Ave is in no way responsible for the policies or practices of third parties. 
    2. Some parts of our Services are provided by a third-party Service Providers, who may collect and record information about your use of our Services.  Additionally, other companies that place advertisements on our Websites, Games and/or Applications may collect information about you when you view or click on their advertising through the use of cookies. We cannot control the activities of such third parties and cannot guarantee that they will adhere to the privacy and security practices which are the same or similar to ours. You should contact them directly if you have any questions about their use of the information that they collect. 
    3. Here are the links to the privacy policies to the sites you might access through our services:
  10. Length of Retention of your Personal Information. 
    1. We will retain your personal information for the purpose for which it was collected to provide you with Services. We may retain your information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.
  11. Privacy of Children’s Data. 
    1. As used in this Privacy Policy, “child” or “children” mean an individual under the age of 13, and the term “parent” includes a legal guardian of a child. 
    2. Our Games and related Services are intended for a general audience. We do not knowingly collect, use, or share any Personal Identifying Information about children without verifiable parental consent or as permitted by law. If you are a parent and you believe your child has provided us with personal information, you can contact us at Email and request your child’s information to be deleted from our system. Once a user indicates that he or she is under the age of 13, we will not collect any personal information from that user except certain limited information permitted by law. Our website and Games are not currently intended for use by children under the age of 13. No one under the age of 13 may provide any information to or on our Services. If you are under the age of 13, do not use or provide any information on or to our Services for any reason. 
    3. California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see your California Consumer Privacy Rights for more information 
  12. Changes to This Policy. 
    1. From time to time, we may update this Privacy Policy to clarify our practices or to reflect new or different privacy practices, such as when we add new features.  We reserve the right to modify and/or make changes to this Privacy Policy at any time. If we make any material change, we will notify you via a notice on our home page or by other appropriate means of enhanced notice if we are required by applicable laws. Changes to this Privacy Policy will take effect immediately upon posting on our website unless we state otherwise in writing. We may update this Privacy Policy from time to time, so you should review this Privacy Policy regularly to ensure you are familiar with any change to it.  The “last updated date” at the top of this Policy will indicate the date that the changes in this Privacy Policy occurred. You hereby acknowledge and agree that your continued access or use of our Services, including any Services available through any third-party platforms, after the effective date of the Privacy Policy update will be deemed an acceptance of and an agreement to the Privacy Policy as changed.
  13. California Resident Privacy Rights.  
    1. California residents have rights as defined in the California Consumer Privacy Act. Those rights include:
      1. The right to request category or specific pieces of personal information 4th Ave has collected about you;
      2. The right to request that 4th Ave delete personal information that we collect, use, disclose, or sell. 
      3. The right to request that 4th Ave delete personal information that 4th Ave has collected about you (subject to certain exceptions). 
      4. The right to opt out of the sale of your personal information. 
    2. To make these requests please contact us at Email where we have a dedicated data security liaison. 
    3. The California Consumer Privacy Act gives residents of the US state of California the right to prevent businesses from selling their personal information to third parties. We may share your personal information with third parties who help us to deliver advertisements in our games for products or services that may be tailored for you. Under the CCPA, this type of sharing of information could be deemed a “sale.”  You can access these, opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.  
  14. EU Data Protection Rights. 
    1. Only the minimum required personal information of users in the EU domain will be collected in order to execute the Games and provide the Services, and any other information will be collected only with the consent of the user. You have the right to object to the way your personal information is processed by 4th Ave by contacting 4th Ave’s Privacy Protection Department. Residents of EU Member States may contact 4th Ave’s Privacy Protection Department for any unreasonable treatment that exceeds the time or other limits required by law.   You may also be able to request judicial relief from the authorities in certain situations. These rights are detailed in the General Data Protection Regulation (GDPR). Please review to learn more about the GDPR and its protections. 
  15. Education Data Protection Rights.
    1.   If you are using our Services through an educational institution, or your child is using our Services through an educational institution you may have certain rights in regard to collected data. These rights include, without limitation:
      1. the right to inspect and review the student’s education records; 
      2. and the right to request that a school correct records which they believe to be inaccurate or misleading; 
    2. Any collection of Data through an educational institution requires written consent. If you believe that your Data is being collected without Written consent, please contact us at Email. 
  16. Contact Information.
    1. To Ask questions or to make a complaint about our Privacy Policy or any of our privacy practices, please feel free to contact us by sending an email to Email.