Privacy Policy


1.1. This Privacy Policy is set out by Marmalade Game Studio Ltd. (including its wholly owned subsidiaries) (“Marmalade”) of 33 Charlotte Street, Fitzrovia, London W1T 1RR as at 20th of January 2020 and as amended from time-to-time per section 1.6. 1.2. The Marmalade Privacy Policy is applicable to the websites, mobile phone or tablet applications, other online product or services, software applications and other software products (collectively “Digital Products”) provided, sold or distributed to you by Marmalade.

1.3. Websites operated by Marmalade use Cookies that enable users to navigate around online properties, and also enables Marmalade to tailor content, marketing and improve user experiences. For further details on Cookies including how to disable them, please see the Cookies section of this Privacy Policy. Please note that without Cookies enabled we cannot guarantee the functionality of our websites, and that your experience whilst visiting it will work as intended.

1.4. By using our Digital Products you confirm that you have read and agree to this Privacy Policy, which includes Marmalade undertaking the following activities: (a) collecting, processing and using demographic information about you such as your age, gender, interests and the IP address that you use, to combine it with your personal information and to use it for analytic and marketing purposes; (b) contacting you from time to time by email to ask for your opinion and inviting you to online polls or surveys, linking the information you provide to your personal information and using this information for marketing purposes © using web beacons (or clear GIFs) on our website or in email messages or placing our own and third party cookies on your computer or device or using flash technology where appropriate to tailor the service to your interests and to select ads and products that are more relevant to you; (d) disclosing your personal information to Marmalade owned subsidiaries and wholly owned group companies; and (e) collecting, processing and storing the personal information you provide on servers in the United States or other countries where Marmalade or its affiliates, subsidiaries, agents or vendors maintain facilities or business operations; in some countries, the data protection level may be lower than in the European Union, but Marmalade will take reasonable measures to safeguard your privacy rights under applicable data protection laws.

1.5. If you do not agree to this Privacy Policy, please do not use the Digital Products. 1.6. Marmalade reserves the right to make changes to this Privacy Policy. If we make a material change to this Privacy Policy, we will post a notice of the change on http://www.marmaladegamestudio.com and also on this Privacy Policy. Your continued use of ©2020 Marmalade Game Studio Ltd. the Digital Products will signify your acceptance of these changes. If you do not agree to any of these changes, please do not continue using the Digital Products. 1.7. This Privacy Policy currently applies to Digital Products operated by Marmalade that post or link to this Privacy Policy 1.8. Please note, however, that this Privacy Policy does not apply to websites or other online properties maintained by other companies or organizations to which we link and Marmalade cannot and does not guarantee the security of any personal information disclosed on those third party sites. In addition, please note that we may solicit third parties to collect personal information on our behalf and in such cases such third parties will be instructed to comply with this Privacy Policy and applicable data protection law. 1.9. Finally, please note that this Privacy Policy applies only to the collection, use and disclosure of information obtained online and not to the collection of information obtained offline. Any collection of information obtained offline will also be in compliance with applicable data protection law.

  1. COLLECTING PERSONAL INFORMATION 2.1. Marmalade only collects personal information from you on a voluntary basis. When you submit personal information to Marmalade, it will usually take the form of:

(a)^ website registration;^ (b)^ contests and promotions;^ ©^ customer service;^ (d)^ software downloads;^ (e)^ purchase of a product or service through our online store;^ (f) use of a website or other online property (including Online Services (as defined below));

or^ (g)^ online submission of your CV/résumé for job openings.^ 2.2. The information we collect may include information such as your name, email address, phone number, work address and home address. In addition, we may collect demographic information such as your age, gender, date of birth and interests. We may also obtain information about you from other sources, as far as such other sources are legally entitled to share such information, and combine that information with information we have collected from you. Once this information is combined it is all considered personal information (“Personal

Information”).^ 2.3. From time to time, we may contact you to ask you for your opinion about certain matters in the form of online polls or surveys, including your opinion with respect to our technology, games or other products and services. Your responses to these polls help us provide products and services of interest to you.

  1. ONLINE SERVICES 3.1. Marmalade may provide you with a variety of online services such as accounts, forums, message boards, and online games (“Online Services”). Marmalade may collect non- personal information from you, such as scores, rankings, game play statistics, game feature usages, and achievements. We may also collect information stored in your account preferences and online profiles, including, for example, your purchases and friends lists. Marmalade may combine non-personal information with personal information in order to tailor advertisements, web pages, game play experiences, products, virtual goods and Online

Services for you.^ 3.2. Further, use of certain features of Online Services, such as messages boards, profiles, and contributing user generated content, may involve disclosure of personal information about you by you. You acknowledge that you have no right or expectation of privacy or confidentiality when using such features of Online Services. ©2020 Marmalade Game Studio Ltd.

3.3. In some instances, we may use a third party service to provide authentication for Online Services, and in such case you may be asked to provide your account information associated with that third party service when signing up for Online Services. In addition, if registering for Online Services directly from a third party gaming service, certain membership information there will be transferred automatically to Marmalade when you register.


4.1. Goods and services purchased through our online store or one of our affiliate online stores will need to provide valid payment details (e.g. a valid credit card number and expiration date), in addition to name, e-mail address, phone number, and home address. Whatever the activity may be, we will only collect information to the extent deemed reasonably necessary to fulfil your requests and legitimate business objectives as permitted under applicable data

protection legislation.^ 4.2. Marmalade may, from time to time, offer you the ability to send an email to friends or family by using an online messaging tool. Any information entered for these messages are used only to send the requested message; we delete both sender and recipient email addresses after sending the message. In using this online messaging tool you confirm that you and party to whom you are sending the message know each other.

  1. REFUSAL TO SUPPLY PERSONAL INFORMATION 5.1. If you do not want to submit personal information that is necessary to provide the service or to fulfil your request, you will not be able to access and/or participate in certain activities. For example, you will not be able to register on http://www.marmaladegamestudio.com or participate in certain contests and promotions or access and/or use other online features or Online Services. In addition, your refusal to submit personal information may limit our ability to respond to your customer support inquiry in a timely fashion.


6.1. Marmalade uses cookies on its websites and other online properties. A “Cookie” is a small amount of record-keeping information that many websites and other online properties often store on a user’s computer or device in order to anonymously identify it and associate activity with it. Cookies typically do not include people’s names, or e-mail addresses.

6.2. When visiting our websites and other online services you can choose whether or not to let us enable cookies. We use cookies to optimize your visit, make your browsing experience as effective as possible, and let you know about offers that we think will interest you. This means that if you refuse, your use of our websites and other online properties may be impaired as a result. 6.3. Depending on the Marmalade website or other online property you are using, and the country you are based in, cookies may be set on your computer or device: (a) to recognize and associate activity with your computer or device when it visits a Marmalade website or other online property; and (b) to enable third party features or functionality to be provided on or through Marmalade’s websites or other online properties (e.g. advertising and analytics). 6.4. Marmalade cookies cannot be used to recognize or associate activity with your computer or

device when it visits other, third party websites or^ online properties.^ 6.5. Third parties that set these cookies can recognize your computer or device both when it visits Marmalade websites or other online properties in question and also when it visits

©2020 Marmalade Game Studio Ltd.

certain other non-Marmalade websites or online properties that use the third party’s features and functionality 6.6. Marmalade will use the following types of Cookies in order to enable a consistent user experience across all of the Online Services. 6.6.1. Strictly Necessary Cookies - These cookies are essential in order to enable you to move around websites or online properties and use their features, such as accessing secure areas of a website. Without these cookies, services such as secure login areas cannot be provided.

6.6.2. Performance (or Analytics) Cookies - These cookies collect information about how visitors use a website or online property, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. Performance Cookies are only used to improve how a website or other online property works. We generally contract with independent research and measurement companies, such as Google Analytics, to provide these services on our behalf and which may

also be subject to their own privacy policies. 6.6.3. Functionality Cookies - These cookies allow the website or online property to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect may be anonymized and they cannot track your browsing

activity on other websites. 6.6.4. Advertising Cookies - These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website or online property operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often advertising cookies will be linked to site functionality provided by the other organization. In certain countries our websites may partner with third party online advertising and analytics companies to tailor and deliver advertisements, products, services, and promotions on our websites and other online properties, as well as advertisements, products, services, and promotions on websites and other online properties which we do not control. To help select the ads of greatest interest to you, these companies may use cookies, Flash technology, and similar technologies to collect and track non-personal information such as demographic information (e.g., gender, occupation, etc.), aggregated information, search keywords, geo-location and online data (for example, clickstream data such as browser type, language, IP address, time/date) to select advertisements that are more relevant to your interests, to better personalize the experience for you and tailor advertisements. In some instances, we may allow third party companies to collect certain anonymous information when you visit our website. These companies may use non-personally identifiable information during your visits to this and other websites in order to provide third party advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or a third party web beacon to collect this information. 6.7. You can review your options to manage cookies by opening the “Help” menu on the browser menu bar. Most browsers will tell you how you can disable or delete cookies or set your browser to alert you when cookies are being sent to your computer. 6.8. If you reject all cookies, you may not be able to use certain features of our websites and other online properties (including sign in).

©2017 Marmalade Game Studio Ltd.

6.9. By using our websites and other online properties you agree, and we will assume you consent, to receive cookies through our websites and online properties unless you manage your cookie

choices as set out above.^ 6.10. If a cookies choice setting is not available then by using the applicable Marmalade website or other online property you agree, and we will assume you consent, to receive cookies through that Marmalade website or other online property. Please also note that the use of information obtained by third party providers through cookies placed by them is also subject to their own

privacy policies.^ 6.11. If you have a registration account with us, information collected by cookies may be associated with your registration account. 6.12. Adobe Flash Player is an application that allows sites to deploy dynamic web content. Adobe Flash and similar applications use cookies to remember settings, preferences, and usage in ways that are similar to browser cookies, but are managed through a different interface than your web browser. You can access your Flash management tools from

http://www.adobe.com/ directly to manage your cookie settings.^ 6.13. From time to time, we may use web beacons (or clear GIFs) on our websites or other online properties or include them in the e-mail messages we send you. Web beacons (also known as “Web Bugs”) are small strings of code that provide a method of delivering a graphic image on a web page or in an email message for the purpose of transferring data. We use web beacons for many purposes, including site traffic reporting, unique visitor counts, advertising

and email auditing and reporting, and personalization.^ 6.14. We also keep track of Internet Protocol (IP) addresses. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the

Internet.^ 6.15. Marmalade may use and share non-personally identifiable (e.g., anonymized or aggregated) information obtained from cookies with third parties such as service providers or advertising partners. An example of the use of such information would be an anonymous group that we assign to an interest categories or segment such as region, gaming preferences, or a combination. We may also share non-personally identifiable information obtained from cookies with third parties such as service providers or advertising networks in order to permit them to provide services on our behalf or to partner with us in selecting and serving advertisements for us or our advertising partners.

6.16. If you have signed in to a social networking site, such as Facebook, it may have set a cookie on your device which recognizes you when you view content on our websites and other online properties. These cookies allow you to share content across social media via the use of sharing settings. See your social networking site’s Terms of Use and Privacy Policy for

details. For additional details, please see 7.8 below.^ 6.17. If you would like to find out more about cookies you may find the following link useful:^ http://www.allaboutcookies.org/

  1. USING PERSONAL INFORMATION 7.1. The information you submit to our websites and other online properties is collected and used

by Marmalade Technologies, Ltd., 200 St John Street, London, EC1V 4RN, UK.^ 7.2. Marmalade may disclose personal information to vendors or employ vendors to collect personal information on Marmalade’s behalf. These vendors provide internal support to our websites and other online properties by operating some of the services we provide you (“Vendors”). When requesting these services, you may be asked to supply your name,

address, e-mail address, and/or other personal information.^ 7.3. In addition, if you are a visitor to our websites and other online properties from outside the U.S., the personal information you provide may be collected, processed and stored ©2017 Marmalade Game Studio Ltd.

directly on servers in the United States or other countries where Marmalade or our affiliates, subsidiaries, agents or vendors maintain facilities or business operations; collected, processed and stored on servers in other countries and then transferred to servers in the United States or other countries where Marmalade or our affiliates, subsidiaries, agents or vendors maintain facilities or business operations. If you do not agree to the collection, processing, storage and transfer of your information, please do not provide your information when requested and stop using our websites and other online properties.

7.4. Marmalade does not share or sell your personal information with outside third parties for those third parties to use for their own purposes without your agreement. Marmalade discloses personal information only in accordance with this Privacy Policy with:

(a)^ Vendors as set out above^ (b) Other third parties as necessary to complete any transaction through our websites or other online properties and/or provide Online Services you have requested. 7.5. Notwithstanding, you agree we may disclose personal information in the good faith belief that we are required to do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability. We may review your account information in order to investigate allegations of cheating, hacking or any other breach or alleged breach of any applicable Terms of Use or this Privacy Policy and disclose your personal information to our legal advisors, consultants and law enforcement or other government officials. In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, Marmalade’s customer information including personal information may be transferred to our successor or other designated party.

7.6. Please note that any information, including personally identifiable information that you reveal in a bulletin board, message board, chat room or other public forum is publicly viewable.

7.7. If you want to remove yourself from individual contests or promotions, or from receiving email newsletters from Marmalade, simply click the unsubscribe link in the email newsletter or access your account from http://www.marmaladegamestudio.com and edit/delete your information accordingly. You will need your password to access your personal account.

7.8. You can also engage with our content on or through third-party social networking sites, such as Facebook and Twitter (or third-party social media plug-ins and applications) (“Social Media”). When you engage with our content on or through Social Media, you may allow us to have access to certain information from your Social Media profile (e.g., name, e-mail address, photo, gender, birthday, location, your list of friends, people you follow and/or who follow you, the posts or the ‘likes’ you make) to deliver the content or as part of the operation of the application. We may also obtain other information from your interaction with our content (e.g., content viewed, game performance, high scores, and information about advertisements within the content you have been shown or may have clicked on).

7.9. When you provide information from your Social Media account, it can help enable us to:^ (a)^ give you exclusive content;^ (b) personalize your online experience with us within and outside our websites (and/or

applications); and^ © contact you in accordance with your marketing preferences through the social networking sites or directly by sending you the latest news, special offerings, and rewards.

©2020 Marmalade Game Studio Ltd.

(^) By doing so, you consent to the use of this information in accordance with our Privacy Policy. When you post personal information publicly through our websites or other online properties, or on social networking sites, it may be publicly viewed by other members of these sites and we cannot prevent further use of the information by third parties. 7.10. Social Media sites and applications will often allow you to control what data you share by changing your privacy settings with that Social Media site or application. For more information about how your Social Media sites and applications use and protect your personal information, please refer to their privacy policies and terms of use.^ 7.11. We partner with certain mobile analytics, advertising, and technology partners. Such mobile partners may use a tracking pixel, agent or any other visitor identification technology that collects, uses, shares and stores data about end users and digital ad campaigns promoting our mobile apps, and by choosing to use Marmalade mobile apps you hereby consent to such activities.^ 7.12. We do not knowingly collect or store any personally identifiable information such as name, address, or e-mail address from children under 13.^ 7.13. We recognize a special obligation to protect personal information obtained from young children. We urge parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when on-line. Children under the age of 17 and over the age of 12 should encourage their parents to review this Privacy Policy and to contact us if they would like to evoke our opt-out policy or to raise any concerns.^ 7.14. From time to time, certain portions of our websites and other online properties may allow all users (including children under 13) to disclose a limited amount of personal information without first telling us their age or getting their parent’s permission. Such portions of our website operate activities or provide services in a way that does not require prior parental consent.^ 7.15. Marmalade takes reasonable steps to ensure data quality such as the accuracy of information obtained from visitors to our websites and other online properties. Marmalade has also taken reasonable steps to maintain all information collected secure and in its original form, i.e. free from any alteration. Access to all personal information is strictly controlled. In addition, we take reasonable steps to assure that vendors who collect personal information on our behalf provide reasonable levels of protection of personal information.^