INTRODUCTION

This Privacy Policy governs the manner in which Courageous Games S.P., A Washington Sole Proprietorship (“Company”, “Courageous Game”, “Us”, “We”, “Halos and Sins”) collects, uses, maintains and discloses your personal information collected from users, customers, clients, and consumers (each, a “User”) of the Halos and Sins application and www.halosandsins.com Website (“App” “Company Service”, “Service”, “Platform”). This Privacy Policy does not describe personal information collection practices on other applications, including those linked to or from our application.

PURPOSE OF THIS PRIVACY POLICY

  1. The purpose of this privacy policy is to help you better understand how we store, collect, and process your personal data. This policy is meant to help you understand more about why we collect and use your data whether you’re a customer or even if you’re just visiting Courageous Games.

In particular, by using our app you consent to our collection and use of your personal information as described in this privacy policy, including any updates or revisions to this privacy policy. This policy does not apply to personal information collected by any third party, including through any application or content that can be accessible from this application.

BY DOWNLOADING, INSTALLING, OR OTHERWISE ACCESSING OR USING THE APPLICATION OR WEBSITE, YOU AGREE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS. IF YOU DO NOT AGREE, YOU MAY NOT USE THE APPLICATION OR WEBSITE. THE COMPANY REQUIRES ALL USERS TO UNDERTAKE TO ABIDE BY THE PRIVACY POLICY AND THESE TERMS & CONDITIONS.

CHANGES TO THIS PRIVACY POLICY

Courageous Games S.P. has the discretion to update this privacy policy at any time. When we do, we will revise the updated date. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

CCPA DISCLOSURE

Under the California Consumer Privacy Act of 2018 (CCPA), Courageous Games S.P. must affirmatively inform California consumers of the categories of personal information collected about the consumer, the sources from which that personal information is collected, the commercial or business purpose for which the personal information is collected, the categories of third parties the personal information will be shared with, and specific pieces of personal information collected about the consumer.

WHO WE ARE

We are a data Processor and Collector. We process data received from our application, and services and take proportionate precaution in storing such personal information on our secure servers until permanently destroyed.

PURPOSE FOR USING YOUR PERSONAL INFORMATION

HOW WE USE COLLECTED PERSONAL INFORMATION

Courageous Games S.P. collects and use user personal information for the following purposes:

  1. To improve customer service
  2. The information provided helps us respond to customer service requests and support needs more efficiently.
  3. To personalize user experience
  4. To improve our App
  5. We use feedback provided to improve our products and services.
  6. To send periodic emails

We use the email address to send User information and updates pertaining to their order. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

INFORMATION WE COLLECT

Our Service collects personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our Platform has collected the following categories of personal information from its consumers within the last twelve (12) months:

  1. Category A: Identifiers
    1. Examples: A name, Internet Protocol address, email address, or other similar identifiers.
    2. Collected: YES
  1. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
    1. Examples: A name, signature, physical characteristics or description, address, telephone number, medical information, or health information.
    2. Collected: NO
  1. Category C: Protected classification characteristics under California or federal law.
    1. Examples: Age (40 years or older), race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, genetic information (including familial genetic information).
    2. Collected: NO

We obtains the categories of personal information listed above from the following categories of sources:

  1. Directly from you. For example, from forms you complete on our Platform.
  2. Indirectly from you. For example, from observing your actions on our Platform or interactions with our advertisers.

PERSONAL INFORMATION WE SHARE

We do not sell, trade, or rent Users’ personal information to others. We do not use third-party service providers to help us to operate our business and the App or administer activities on our behalf, such as sending out newsletters or surveys. We will share your information with third parties only in the ways that are described in this Privacy Policy

  1. Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy.
  2. Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, any third party to which we sell or transfer our assets to will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy Policy.
  3. Required by law: In addition, we may disclose your information to the extent that we are required to do so by law; in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights.
  4. Digital Content Stores: Where the Games are downloaded though Google Play, Apple Store and/or Amazon Appstore, we may disclose your personal information to Google, Apple and/or Amazon respectively for the purposes of facilitating any in-Game payments made through these platforms.

AUTOMATED DECISION MAKING

We use automated decision making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy. We process your personal information via automated decision making methods in order to identify users who are suspected of cheating in the Games. Our automated decision making methods are designed to detect cheating by looking out for (i) excessive currency stores against actual completed gameplay; and (ii) excessive content against actual purchases made and completed gameplay.

If users are determined to be or suspected of cheating the following actions may be taken and which will be unknown to the user. We may block users from the Games and/or the Online Services who are determined to be cheating following an automated decision process. In this scenario the user will be notified of the outcome and will have the right to obtain human intervention to express his or her point of view and

COOKIES

The collection of this information may include the use of cookies and similar technologies (for example, which are used on the Website). A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Cookies are widely used in order to make websites work, to provide functionality, to make them more efficient and to provide website owners with information about how the website is being used and who’s using it. We use a limited number of cookies on our website.

ADVERTISING PURPOSES

We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games.

The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify you or permit you to be treated individually. We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games.

We will not pass or process your information for the purposes of marketing by third parties unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.

If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.

PREVENT FRAUD AND ILLEGAL ACTIVITY

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and also in order to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances. We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through Apple Store and Google Play).

CATEGORIES OF PERSONAL INFORMATION COURAGEOUS GAMES COLLECTS

When you engage in certain activities via the Company Service, including but not limited to creating an account, sending feedback, or otherwise participating in the Company Service (collectively, “Identification Activities”), we will ask you to provide certain information about yourself. We also collect the following:

  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Transaction Data
  • Assessment Data
  • Profile Data
  • Marketing and Communications Data

If you elect to use our service we will ask you to provide us with certain personal information about yourself, such as your user names, gender, email address, and/or any other information you provide to us, to process your transaction, send communications about them to you, and populate forms for future transactions. We may also ask you to provide us with additional information, such as credit card information for future paid features. If you do not provide mandatory information for an Identification Activity, you will not be permitted to engage in that Identification Activity with the Company Service.

DATA RETENTION

Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall be kept until such time as we receive a request for deletion from you. Notwithstanding the other provisions, we will retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

APPLE OR IOS SOFTWARE

By accessing this App through a device made by Apple, Inc. (“Apple”), you specifically acknowledge and agree that: (i) this Agreement is between Company and You; Apple is not a party to this Agreement; (ii) Apple and its subsidiaries are third party beneficiaries of this Agreement and upon your acceptance of the terms and conditions of this Agreement, Apple will have the right (and will be deemed to have accepted the right) to enforce this Agreement against you; (iii) the license granted to you hereunder is limited to a non-transferable right to use the App on the Apple device(s) authorized by Apple that you own or control and as permitted by the Usage Rules set forth in Apple’s App Store Terms of Service; (iv) Apple has no obligation whatsoever in connection with the functionality or content of the App, or to furnish any maintenance or support services with respect to the App; (v) in the event of any failure of the App to conform to any applicable warranty, you may notify Apple, and Apple will refund the amount you paid for the App, if any (to the maximum amount permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the App); (vi) Apple is not responsible for addressing any claims by you or a third party relating to the App or your possession and/or use of the App, including without limitation (a) product liability claims; (b) any claim that the App fails to conform to any applicable legal or regulatory requirement; and (c) claims arising under consumer protection or similar legislation; (vii) in the event of any third party claim that the App or your possession and use of the App infringes such third party’s intellectual property rights, Apple is not responsible for the investigation, defense, settlement and/or discharge of such claim.

YOUR LEGAL RIGHTS

Your principal rights under data protection law are:

(a) The right to access;

(b) The right to rectification;

(c) The right to erasure;

(d) The right to restrict processing;

(e) The right to object to processing;

(f) The right to data portability;

(g) The right to complain to a supervisory authority; and

(h) The right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting your profile when logged in.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. To the extent that the legal basis for our processing of your personal data is:

(a) Consent; or

(b) That the processing is necessary for the performance of a service.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

INTERNATIONAL PRIVACY LAWS

If you are visiting the Services from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy.

DISPUTE RESOLUTION

If you have a complaint about Courageous Games S.P.’s privacy practices you should contact us. We will take reasonable steps to work with you to attempt to resolve your complaint in accordance with the “Terms” incorporated with these policies.

GENERAL DATA PROTECTION REGULATION (GDPR)

The GDPR requires Courageous Games S.P. and Servicers using the Service to provide Users with more information about the processing of their Personal Data. The GDPR requires us to tell you about the legal ground we’re relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out above will typically be because:

  • You provided your consent; it is necessary for our contractual relationship;
  • The processing is necessary for us to comply with our legal or regulatory obligations;
  • And/or the processing is in our legitimate interest as a service platform.

NEVADA RESIDENTS

Under Nevada law, certain Nevada residents may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, or an identifier that allows a specific person to be contacted either physically or online.

We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing us. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

RIGHTS FOR CALIFORNIA RESIDENTS

If you are a California resident, the California Consumer Privacy Act (CCPA) may provide you with additional rights regarding the use of your personal information. These rights include:

  • The right to access the personal information we process about you
  • The right to know what personal information is collected about you and if any information is sold or disclosed, and to whom
  • The right to request the deletion of your personal information
  • The right to opt-out from the sale of your personal information
  • The right to not be discriminated against for exercising any of the rights above

You can exercise any applicable rights by emailing support@halosandsins.com or sending a letter to the address below. You may be required to submit proof of your identity and/or address, if we are unable to confirm your identity or cannot verify that you are a California resident. We will try to respond to a verifiable consumer request within 45 days of its receipt.

TRANSFERS OF PERSONAL DATA

As Courageous Games S.P. is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland and the UK which have no data protection laws or laws that are less strict compared with those in Europe.

CHANGE OF OWNERSHIP

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.

HOW TO OPT OUT OF FUTURE COMMUNICATIONS

Consumers may opt-out of notifications and personal information storage at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least six (6) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our service and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

SECURITY OF YOUR INFORMATION

You can access your Personal Information via the Company Service with your password and username. If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanism appropriately and limiting access to your mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user personal information at any time.

If we believe that the security of your personal information may have been compromised, we may seek to notify you of that development. In addition, your Personally Information resides on a secure server that only selected personnel and contractors have access to.

We encrypt certain sensitive information using SSL technology and AWS Cloud Technology to ensure that your Personally Information is safe as it is transmitted to us. However, no data transmission can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies that do the same, we cannot guarantee the security of any information transmitted to or from or via the Company Service, and we are not responsible for the actions of any third parties that may receive any such information.

CHILDREN’S PRIVACY

If you are a minor, please do not provide us or other service visitors with any personal information and do not use this service. We do not knowingly provide services or sell products to children. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we have any information from or about a child under 18, please contact us at support@halosandsins.com.

EXTERNAL LINKS

Users will find advertising or other content on our Site or application that may link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by applications or websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services will have their own privacy policies and customer service policies. Interaction on any other application, including applications which have a link to our Site, is subject to that application’s own terms and policies.

COMPLAINTS & CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Halos and Sins

Courageous Games S.P.

PO Box 1955

Issaquah, WA. 98027

support@halosandsins.com

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