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Bagelcode, Inc. Privacy Policy
Last modified: Jun 29, 2021

In this Privacy Policy, Bagelcode, Inc. ("Bagelcode") provides important
information on how information is collected, used, and disclosed when you visit
or use a Bagelcode’s game or application ("Service"). Please read this
carefully. By accessing and/or using Bagelcode website or any Bagelcode Service,
you are accepting the practices described in this Privacy Policy.

The term "Bagelcode" means Bagelcode, Inc. and/or its Affiliates. The
term "Affiliate" means subsidiaries, parent companies, joint ventures, and any
other parties, persons, or corporate entities in common control of, by, or
with Bagelcode. The term "Bagelcode Service" or “Service” means the websites
of Bagelcode, including www.bagelcode.com, any other sites on which this Privacy
Policy is posted, and any other Bagelcode application, service or product
licensed, downloaded or otherwise accessed by you through third party sites or
sources, including the products and services available through any of the
foregoing.

By using the Service, you agree to the collection, disclosure, storage and use
of your information as outlined in this Privacy Policy. If you do not want
Bagelcode to collect, store, use or share your information in the ways described
in this Privacy Policy, you should not play Bagelcode’s games or use our
Services.

INFORMATION WE MAY COLLECT

When you use our Website or any Bagelcode Service, we may collect Personal Data
about you. We have set out below what data we collect and how we collect it.


Personally Identifiable Information:

We may collect the following information when you sign up with a Bagelcode
Service: first and last name, date of birth and/or age range, gender, email
address, social network or third-party service user identification number,
transaction related information for purchases, any other information shared with
us by third-party social network or other online applications.

Technical Information on User’s Device:

When a user accesses a Bagelcode Service, we may collect technical information
about the user’s device, such as the IP address that requested the display of
the Bagelcode Service, the operating system type, and the identifiers associated
with the device.

Sign Up and Survey Information:

Any information you provide to us, and any information you choose to share about
yourself as part of your use of any Bagelcode Service, may be stored as entered.

Chat Conversations:

We collect information about your communications via our Website or any
Bagelcode Service, including in our chat and messaging facilities (including the
content of any messages you send or post).

Email Communications:

We collect and store all copies of emails you send to us and our replies to your
emails.

Cookies and Web Beacons:

Cookies are small data files placed on your device's browser to enable our
systems to recognize your browser, track for internal purposes, advertise more
efficiently, and to provide important features. Third-party or partner websites
may also place cookies. We may use Adobe Flash cookies to remember your
settings, preferences, and usage within a Bagelcode Service. Web
beacons, clear.gifs or similar technologies are small pieces of code that we and
our service providers may place on a Bagelcode Service to monitor and collect
data about visitor behavior within the Bagelcode Service.

We may receive a confirmation when you open email from Bagelcode, if your
computer supports such capabilities. We may also track other types of
information, such as game download and install activity, download errors,
purchase records, time and date activity, session lengths, and other user
behavior and gameplay, such as whether a user has won any of our games,
sweepstakes, contests or other promotions featured on a Bagelcode Service, ad
response measurement and other Bagelcode Services analytics.

Social Networking Sites:

If you access a Bagelcode Service via a third-party social networking site (a
"Social Game"), Bagelcode may receive information about your social networking
site profile and other information shared by the third party, including your
social networking site user ID, first and last name, profile and cover photos,
and e-mail address provided to the Social Game. If you invite new members into
your Social Games network or send messages through Social Games, we may collect
the information associated with those messages, including your friends' social
networking site user IDs, email addresses and content.

Mobile:

When you download or access Bagelcode Services via a mobile device, we and our
service providers may receive passive information about your geographical
location (based on your IP address) and your mobile device, including various
unique identifiers associated with your device, hardware type, the version of
your operating system, and your in-game activity. We and our service providers
may use this information to provide you with personalized advertising and other
content, including advertising and content based on your location.

Marketing Data:

We collect information in relation to your response to the marketing activities
carried out by us (e.g. marketing campaigns, competitions, offers, etc) such as
information about when you open your email communications etc.

Aggregated, Anonymous Information:

We may collect aggregated, anonymized information via Bagelcode Services that do
not identify any single user or device. If you choose to provide a username
within a Bagelcode Service, please do not provide as your username any
information that identifies you in real life, such as your real name.

HOW WE USE AND SECURE COLLECTED INFORMATION


Bagelcode collects, stores, and uses information for various purposes including
providing improved gaming experience. We may use your username, email address,
and password to uniquely identify you as a user on a Bagelcode Service, to
provide you with services and to process transactions. We may use or display
your username and icon or profile photo, if applicable, for the purposes of
rankings, competitions or sweepstakes, chat identification, and/or game high
scores. We may also use or display your username and icon or profile photo for
marketing purpose or press releases. Your username, profile and icon or profile
photo may also be displayed in any Bagelcode Service. We may use your date of
birth to confirm your eligibility to participate in Bagelcode Services.

Subject to the terms of this Privacy Policy, we may use your contact information
to process our promotional newsletters and/or email campaigns and to send you
updates, security alerts, or administrative messages relating to Bagelcode
Services. Your contact information will allow us to notify you about new
features, enhancements, or resolution of Bagelcode Services problems, to handle
and/or route your customer support questions and issues, and inform you of
upgrade opportunities, sweepstakes, contests, prizes, and/or special events.

If our "Tell a friend" feature is available within a particular Bagelcode
Service, and you choose to participate in it, your email will be shared with the
person to whom you send the Bagelcode Service using this feature. We may use an
IP address to surface the appropriate country-based version of a Bagelcode
Service to a user, or to exercise our ability to restrict access to the site by
users who have violated our Terms of Use.

We and our third-party service providers use cookies and other technologies,
such as mobile device identifiers, to enhance your experience with Bagelcode
Services. These technologies enable us and our service providers to run our
affiliate programs and provide you with customized content or offerings, such as
personalized Bagelcode advertisements on other websites and mobile applications
and personalized third-party advertisements within certain Bagelcode Services.
Cookies also enable you to automatically sign in when you access a Bagelcode
Service and offer other operational activities within a Bagelcode Service. We
and our third-party service providers may also use cookies and other
technologies to manage and measure the performance of third-party advertisements
within certain Bagelcode Services and Bagelcode advertisements on third-party
sites and mobile applications. This helps us and our service providers provide
more relevant advertising to you. We and our third-party service providers may
also use web beacons to monitor user behavior and collect information about
visitors viewing a web page.

We may use information collected to calculate aggregate, anonymized statistics
about our user community for the purpose of enhancing our Bagelcode Services, or
for security purposes.

If you access a Social Game, we may use your social networking site profile ID
to link your social networking site account with your activities within the
Social Game or offer personalized Bagelcode advertisements on the social
networking site. We may use your social networking site first, last and user
names and icon to identify you to the social networking site account you've
linked to your activities within the Social Game, as well as for the purposes of
rankings, competitions, sweepstakes, game high scores and/or identification to
your social network.

If you access a Social Game and provide us with another person's contact
information for purposes of delivering information through a Social Game, we may
use this information to contact, and if necessary, remind that person that he or
she has been invited to join a Social Game, or received content through a Social
Game. All invitees are provided with the option not to receive further
invitations from Bagelcode.

We at Bagelcode take reasonable measures to help protect the information we
collect from loss, theft, misuse and unauthorized access, disclosure,
alteration, and destruction.

SHARING INFORMATION

 

We may share customer information with Bagelcode Affiliates, as described below.

Third-Party Marketplaces and Service Providers:

We may disclose your personal information as well as aggregate, anonymous
information to third-party business partners, marketplaces, and third parties
who perform services for and on our behalf, such as payment processing, prize
fulfillment, delivering packages, sending postal mail, collecting and analyzing
data, optimizing game play, providing search results and links (including paid
listings and links), and providing advertising and marketing assistance,
including serving ads on our behalf on third-party websites and mobile
applications and serving ads on behalf of third parties within certain Bagelcode
Services. Those third parties have access to your personal information only as
necessary to perform their functions, and for no other purposes.

Business Transfers:

As Bagelcode continues to grow, we might sell or buy certain subsidiaries and/or
business units. In such transactions, customer information is generally one of
the transferred assets. Also, in the unlikely event that Bagelcode, or
substantially all of its assets, are acquired, customer information would in
most cases be one of the transferred assets.

Protection of Bagelcode and Others:

We may be required to also disclose your information if there is a violation of
the Terms of Use or other agreements; if we have belief that the law requires
it; or if needed to protect the rights, property or safety of Bagelcode, our
customers or others. This includes exchanging information with entities for
fraud detection and protection, and credit risk reduction.

ACCESSING, UPDATING, AND MANAGING YOUR INFORMATION

 

Bagelcode enables you to access a wide range of information about your account
and your interactions with Bagelcode Services. You may contact us about your
information and your intentions for limiting the use and disclosure of your
information by emailing us at support@bagelcode.com.

Promotional Email Communications:

When you create a customer account or provide access to your email address via a
Bagelcode Service, you may be automatically registered to receive one or more of
our promotional e- newsletters. Note that when you provide an email address
through a Bagelcode Service, we treat that as a request to be enrolled in one of
our promotional e-newsletter lists, even if you previously opted out of
receiving newsletters from us. If you change your mind and wish to opt out
again, you may do so at any time by clicking the "unsubscribe" link at the
bottom of any newsletter, and then following the instructions provided. If you
express interest in a Bagelcode Service by clicking on a banner within a
newsletter, you may be automatically registered to receive newsletters relating
to the Bagelcode Service that appeared in the banner.

At any time, you may opt-out of receiving a newsletter by selecting the
"unsubscribe" link at the bottom of any newsletter. We treat each Bagelcode
Service individually, so if you are receiving mailings from more than one
Bagelcode Service, and you want to unsubscribe, you must do so with respect to
each individually. You may also contact us at support@bagelcode.com Please note
that we reserve the right to send you non-promotional, account or administrative
emails even if you opt out of receiving promotional e-newsletters.

Cookies, Online Advertising and Analytics:

Please refer to your browser settings and help section to learn about blocking,
erasing or being notified of cookies. However, because cookies allow you to take
advantage of some of Bagelcode Services' essential features, we recommend that
you leave cookies turned on. For example, you may not be able make purchases on
Bagelcode Services without having cookies turned on. To opt out of receiving
personalized advertising from many ad networks, data exchanges, marketing
analytics and other services providers, please visit aboutads.info.

Mobile Advertising:

Most mobile devices provide the ability to opt out of the collection and use of
information from the apps you use for purposes of serving ads targeted to your
interests. For more information, and to exercise these choices, consult the
settings on your device.

Social Games:

With respect to Social Games, you may manage your own social network privacy
preferences through your social networking site account.

THIRD PARTIES

 

Bagelcode Services may allow you to play or share information through social
media (such as by logging in through a social media account or using a "Like"
button) or contain links to social media services or other third parties. The
use of these features and links are subject to the privacy policies of those
companies and your settings on those services. Bagelcode has no control over,
and is not responsible for, the information submitted to or collected by social
networks or other third parties. We encourage you to review those third-party
privacy policies to understand the way your information may be collected and
handled by such third parties.

CHAT & MESSAGING FEATURES

 

Bagelcode Services may operate message boards and/or chat areas where users can
exchange ideas and communicate with each other. When partaking in such
communication features, you acknowledge that the information is being made
publicly available in an online environment. Any information posted is the sole
responsibility of the individual user.

CHILDREN

 

Bagelcode Services do not knowingly collect "personal information" as defined in
the Children’s Online Privacy Protection Act ("COPPA") from children under 13,
other than when permitted by COPPA, like for support of internal operations. If
you are under 13, you may not register for an account or otherwise provide any
personal information to us.

Bagelcode respects the privacy of parents and children and is committed to
complying with COPPA. If a parent believes that his or her child has submitted
personal information to Bagelcode, he or she can contact us via email
at support@bagelcode.com. We will take reasonable measure to promptly remove the
information upon learning that it was inadvertently gathered from a child under
the age of 13. We recognize the importance of safeguarding the privacy of
children and encourage parents to check and monitor their children's use of
online activities regularly.

GDPR

The General Data Protection Regulation (GDPR) introduces obligations that will
impact companies around the world. This law offers a common framework across the
European Union (EU) for organizations exposed to personally identifiable
information (PII) relating to individuals located in the EU. The GDPR sets a new
level and cost of accountability that all organizations - even those that don't
do business in Europe - must pay attention to.

If you want to review, delete, or change the information Bagelcode has about you
or have additional questions, contact us via email at support@bagelcode.com and
we will respond to your request within thirty days.

You, as a user, have the right to:

- Review your personal data
- Correct errors in your personal data
- Object to processing of your personal data
- Erase your personal data



You can erase your personal data any time. Please be advised that by deleting
your personal data, all game progress, and virtual goods or currency paid for
and/or earned across ALL Bagelcode games will be terminated. Copies of some
material (example: log records) may remain in our database but are disassociated
from personal identifiers.

Data Retention

We will not keep your Personal Data for longer than required. The precise
duration for which we keep your Personal Data when you have a live member
account with us or for a period after you cease to be a member with us, can vary
and depends on various reasons. To determine the appropriate retention period
for Personal Data, we consider the amount, nature and sensitivity of the
Personal Data, the potential risk of harm from unauthorized use or disclosure of
your Personal Data, the purposes for which we process your Personal Data and
whether we can achieve those purposes through other means, and what the law
requires us to do. For example, we retain a copy of your Member Account’s
records of all financial and wagering transactions together with any
identification provided for as long as is necessary for the relevant service and
for no longer than 7 years after you have closed your Member Account.
When we no longer need to keep your Personal Data, we anonymize it securely and
this process cannot be reversed. Additionally, where we decide to retain your
information for analytics purposes, we will fully anonymize it in accordance
with applicable security standards, so it can never be linked back to an
individual.

Please note that if you decide to opt-out from receiving marketing
communications from us, we will need to retain a copy of your contact details,
so we can add them to our suppression list and make sure you do not receive any
information about our future marketing activities.

Please contact support@bagelcode.com if you need any further information.

AGREEMENT WITH BAGELCODE POLICIES

 

By accessing and/or using any of the Bagelcode Services, you signify your
understanding of and agreement with this Privacy Policy, and to our Terms of
Use. If you do not agree with our policies, please do not access or use any
Bagelcode Services.

CHANGES TO PRIVACY POLICY

 

We may revise this Privacy Policy at any time, as we deem appropriate. When we
post changes to this Privacy Policy, we will revise the "last modified" date at
the top of this page. We advise you to regularly review this Privacy Policy to
be informed of how Bagelcode collects, uses, and secures your information.