Bagelcode, Inc. Privacy Policy
Last modified: Jun 27, 2025  

INTRODUCTION

 

This Privacy Policy provides important information about how Bagelcode, Inc. and its affiliates (“Bagelcode”, “we”, “us”, and “our”)  collects, stores, transfers, shares, uses, and otherwises processes data that identifies or is associated with you ("personal information") when you visit or use Bagelcode’s websites or applications, including www.bagelcode.com, any other sites on which this Privacy Policy is posted, any 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.

 

Depending on your region, we may choose or be required by law to provide different or additional disclosures to you. Please refer to the Region-Specific Disclosures section below for additional disclosures that may be applicable to you.

 

This Privacy Policy does not address our privacy practices related to Bagelcode job applicants, employees, and other employment-related individuals nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Policy is not a contract and does not create any legal rights or obligations not otherwise provided by law.

 

OUR COLLECTION AND USE OF PERSONAL INFORMATION

 

The categories of personal information we collect depend on how you interact with us and our Services. For example, when you interact with us directly, you may provide us certain information about you (e.g. your contact information or account registration information). We also collect personal information automatically when you interact with our websites and other services and may also collect personal information from other sources and third parties.

 

Personal Information You Provide to Us

 

We collect the following categories of personal information individuals provide us:

·       Contact information and identifiers, including: first and last name, email address and communication preferences. We use this information to communicate with you (including to send you marketing materials in accordance with your communication preferences), to fulfil your requests and transactions, and for support purposes.

·       Account information, including: username and password. We use this information primarily to administer your account, and to provide you with products and services. 

·       Profile information and gameplay, including your screenname, date of birth and/or age range, gender, country, user description and avatar or profile photo; your in-game scores, achievements and purchases; the competitions you enter and your membership and participation in teams on the Services. We use this information primarily to provide you with products and services and to fulfill your requests or transactions.

·       Your interactions with social and chat features, including: your connections and connection requests on the Services, messages you send and receive on the Services, and any content you upload in relation to the social and chat features. We use this information to provide you with chat and social features of the Services at your request.

·       Transaction related information for purchases, including: transactions you make on the Services, date and time of transactions, account ID, and order ID, etc. We use this information to fulfill your transactions made on the Services and for the purposes of our security monitoring and fraud detection.

·       Your communications with us, such as your comments and questions and requests for support. We use this information to provide you with customer service, and to improve our Services.

·       Survey Information, including feedback and ratings you provide relating to our Services. We use this information to improve our Services and to provide new products and features for the benefit of our users.

·       Participation in competitions, sweepstakes, and events. We collect information on your participation in competitions, sweepstakes, and events (e.g VIP promotions) to provide you with these services, and to administer your participation in them (including administering any prizes).

·       Inferences, such as information generated from your use of the Services, reflecting predictions about your interests and preferences. We use this information to suggest products and services that may be of interest to you.

 

Personal Information We Collect Automatically 

 

We typically collect certain personal information automatically through a variety of tracking technologies when you use our websites and applications or interact with our Services, including (i) cookies or small data files that are stored on an individual’s device or computer (ii) mobile software development kits and (iii) other, related technologies, such as pixels and logging technologies (collectively, “tracking technologies”). In some circumstances, we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

 

Depending on which of our Services you interact with, we may collect and process the following types of information:

 

·       Analytics and Usage Data, including details about how you use and interact with our website, games, advertising and other Services, including Services you access via a third-party social networking site (a "Social Game") (such as the time you access the Services and how long you access it for, the approximate location that you access the Services from, the site / applications from which you came and the site / application to which you are going when you leave the Services, the pages you visit, the links you click, your interactions on the Services (including with other players) and other actions you take on the.

·       Device Data, including the tablet, smartphone or other electronic device you use to connect to the Services. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Services through the device, your mobile network, your IP address and your device's telephone number (if it has one), as well as your unique device ID (persistent/non-persistent), Apple Identifier For Advertising (IDFA), Android Advertising ID (AAID), App Set ID and/or Google Advertising ID (GAID) and game centre ID.

·       Approximate Location Data, including your location such as the city, region and country you are in) based on your Internet Protocol ("IP").

 

All of the information collected automatically through these tools allows us to improve your user experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Services, and to improve the effectiveness of our Services, offers, advertising, communications and customer service. We may also use the information collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Services; (b) provide custom, personalized content and information, including personalized and contextualized content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.

 

Personal Information We Collect from Third Parties

 

We may also obtain personal information listed above and other supplementary information from third parties, which we often combine with personal information we collect either automatically or directly from an individual. For example, we may receive the same categories of personal information described previously, or the below categories of personal information from the following third parties:

 

·       Business Partners. We may receive your information from our business partners, such as companies that offer their products or services on our Service or marketing/advertising and analytics partners, including third-party brands/agencies or other partners that facilitate the buying and selling of advertising inventory on our Service, measure of the effectiveness of those related ad campaigns, or inform business analytics (e.g., view rates, bounce rates, audience composition, etc).

·       Social Networking Sites. If you access a Social Game, Bagelcode may receive information about your social networking site profile and other information shared by the third party, including: (a) Social Network Identifiers and Profile Information, such as your social networking site user ID, first and last name, profile and cover photos, and e-mail address provided to the Social Game, (b) if you invite new members into your Social Games network or send messages through Social Games, we may collect Social Network Invites and Interactions, including the information associated with those messages, and your friends' social networking site user IDs, email addresses and content. We may use this information to allow you to log into your account, to communicate or interact with individuals on the social network, to better understand the demographics of our visitors, and to personalize content and advertising. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information or linking or connecting them to other services, and (c) Social Network Login Information, such as Facebook friends’ List, Facebook profile photo, and Facebook / Apple data used to log in, etc. We use this information to authenticate you to the Social Game.  

·       Payment Services. Third party platforms that provide us with payment services (for example PayPal, Appcharge, Xsolla, etc) enable us to process your payment for purchases, for example what you have purchased, and when you purchased it. In some instances, we may also receive additional information provided at the point of purchase. If you are unsure what information a third party is sharing with us, please consult their privacy policies/notices and your account settings.

·       Third Party Platform with in-app Purchasing Services (for example Apple and Google) enable us to process your payment for purchases, for example information about what you have purchased, and when you purchased it. If you are unsure what information a third party is collecting and sharing with us, please consult their privacy policies/notices and your account settings.

·       Information Providers. We may, from time to time, obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual or obtain demographic information (e.g., interests, preferences).

·       Other Sources. We may also collect personal information about individuals from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions or other corporate transactions. We may receive your information from other users who interact with our Service.

 

ADDITIONAL USES OF PERSONAL INFORMATION

 

In addition to the purposes for using personal information described above, we may also use personal information we collect as follows:

 

·       Bagelcode 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 purposes 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 you choose to invite new users to a Social Game, we may collect information to allow them to participate in the Social Game. Your email will also be shared with the person to whom you send the Bagelcode Service using this feature.

·      We and our third-party partners use your information to enhance your experience with Bagelcode Services. This information enables us and our third-party partners 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 partners may also use your information 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 third-party partners provide more relevant advertising to you. We and our third-party service providers may also use your information 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.

·       We may use your information to understand our users and to tailor or optimize the Bagelcode Services. For example, we may analyze statistics and trends to make the Bagelcode Services better and to develop or better personalize the Service or new services or features.

·       We may use your information to protect our company, our affiliates, and the Bagelcode Services.  We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, protect and defend our rights and property, or the rights or safety of third parties, enforce our Terms of Use, this Privacy Policy, or agreements with third parties, detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law. 

·       We may use your personal information for any other purposes at your direction or where notice is otherwise provided.

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

 

OUR DISCLOSURE OF PERSONAL INFORMATION

 

In addition to the disclosures contemplated elsewhere in this Privacy Policy, we may disclose customer information as described below. To provide you with and enhance our Services, we may share information with our service providers and/or business partners for analytics, marketing, and other business purposes.

 

·       Third-Party Service Providers and Partners. We may disclose your personal information as well as aggregate, anonymous information to third-party business partners (including advertising 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 gameplay, 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.

·      Advisors, such as legal advisors or accountants. These advisors will use your personal information to provide advisory services to us.

·       Advertisement Partners. To assist with the functionality of advertisement, as well as run, measure and optimize our own marketing campaigns and undertake performance analytics, our advertising partners may collect (or we may share with them) information such as Advert performance information, device identifiers (IP addresses, IDFAs, GAIDs), gameplay activity and game events, social media identifiers.

·       In Connection with Business Transactions or Reorganizations. 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, is acquired, customer information would in most cases be one of the transferred assets.

·       Affiliates. We may share personal information with our Affiliates, particularly when we collaborate in providing the services.

·       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. In addition, we may share information to satisfy our legal obligations and comply with law enforcement.

·       With Your Consent or Direction: We may disclose your personal information to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites.

 

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. Please refer to our Region-Specific Disclosures below for information about additional privacy choices that may be available to you.

 

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. If you want to opt out, 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 can do so with respect to each individually. You may also contact us at support@bagelcode.com. 

 

Additionally, please see our “Your Privacy Request” link (found in the website footer) to exercise your opt-out rights accordingly, or to ask any other privacy related requests. You can also request opt out of all marketing emails through this request. 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

 

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources at https://www.aboutads.info/choices (or https://www.youronlinechoices.eu/ or https://youradchoices.ca/en/tools for the EEA and Canada, respectively) or the Network Advertising Initiative’s (NAI) online resources at https://www.networkadvertising.org/choices/. You can also opt-out of receiving some interest-based advertisements on mobile apps by visiting https://www.aboutads.info/appchoices. You may also be able to opt-out of some interest-based advertising served by participating mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.

 

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us (or our third-party partners) or on our online services in general. It means that the online ads that you do see from self-regulatory program participants (or other participants that may provide an opt-out mechanism) should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs, or the accuracy of their statements regarding those options or programs. In addition, third parties may still use cookies or other tracking technologies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under those self-regulatory programs.

 

Mobile Advertising

 

Most mobile devices provide the ability to opt out of the collection and use of certain 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.

 

CHAT & MESSAGING FEATURES

 

Bagelcode Services may operate message boards and/or chat areas where users can exchange ideas and communicate with each other. When participating 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" from children under 17, other than when permitted by applicable law, like for support of internal operations. Bagelcode respects the privacy of parents and children. If you are under 17, you may not register for an account or otherwise provide any personal information to us, and we do not knowingly collect or solicit personal information from anyone under the age of 17+ or knowingly allow such persons to register for use of the Service.

 

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 measures to promptly remove the information upon learning that it was inadvertently gathered from a child under the age of 17. 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.

 

DATA RETENTION

 

We may retain information for as long as you use our service and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our legitimate business purposes and applicable laws. The duration of personal information processing depends on the type of service provided and the purpose of processing.

 

As a rule, the data is processed for the duration of the service provision or order processing, until the withdrawal of the expressed consent or filing an effective objection to data processing. We retain a copy of your account records of all financial and legal transactions together with any identification provided for as long as is necessary for the relevant service and during the period required by law after you have closed your account. The duration of data processing may be extended if the processing is necessary to establish and assert possible claims or to defend against claims, and thereafter only in the case and to the extent required by law. After the end of the processing timespan, the data is irreversibly deleted or anonymized.

 

When we no longer need to keep your personal information, 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.

 

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.

 

LINKS TO THIRD PARTY SITES

 

The Services may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, social media platforms, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

 

REGION-SPECIFIC DISCLOSURES

 

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

 

-      United States: If you are a resident of the United States, please check for additional U.S.-specific privacy disclosures, including a description of the personal data rights made available to residents of certain states under applicable law.

-      European Economic Area, United Kingdom or Switzerland: If you are located in the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), the United Kingdom, or Switzerland, please check for additional European-specific privacy disclosures, including a description of the personal data rights made available to individuals located in those jurisdictions under applicable law.

 

CONTACT US

 

If you have any questions, comments, concerns or complaints regarding our Privacy Policy or any other privacy issue please contact us at support@bagelcode.com, or by “Your Privacy Request” link.

 

 

 

 

 

ADDITIONAL U.S. DISCLOSURES

 

For residents of the state of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, this U.S. State Privacy Notice supplements the information contained in our Privacy Policy by providing additional information under the consumer privacy laws of those states as and when they are effective (the “State Privacy Laws”).

 

Your Privacy Rights

 

Depending on your state of residency, you may exercise the following rights under the State Privacy Laws in relation to the personal information about you that we have collected about you (subject to certain limitations under such laws, such as exceptions in the State Privacy Laws or the inability to verify your identity):

 

The Right to Access	Under the State Privacy Laws, you have the right to obtain confirmation regarding whether we are processing your personal information and to access that personal information. You also have the right to access that personal information in a portable, readily usable format, unless not technically feasible to provide in such a format. Under certain laws, you may also have the right to request the following: (a) the specific pieces of personal information the business has collected about you and (b) the categories of personal information collected, the sources of collection, the business/commercial purpose for collecting or "selling/sharing" personal information, and the categories of third party to whom the business discloses personal information.
The Right to Deletion	You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions under the State Privacy Laws.  Each request will be handled properly according to our internal guidelines
The Right to Correction	You have the right to request that inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information. Each request will be handled properly according to our internal guidelines
Opt-Out Rights	Under State Privacy Laws, you have the right to opt-out of “sales” and “shares” of personal information, “targeted advertising,” and certain use/disclosure of “sensitive” personal information. As further described in this Privacy Policy, we disclose the following to our advertising/marketing and analytics partners (e.g., advertisers/agencies, social media networks, Adtech partners) for advertising and marketing purposes, including direct marketing: Identifiers, commercial information, geolocation data, internet or other network information, and data that may be considered “sensitive” personal information under certain State Privacy Laws. Please see our “Your Privacy Request” link (found in the website footer) to exercise your opt-out rights accordingly. There should be no significant disadvantages even if you choose to proceed this way. We do not have actual knowledge of “selling” or “sharing” personal information of consumers under eighteen (18) years of age. We only use or disclose sensitive personal information where reasonably necessary and proportionate for the purposes of providing products and performing services you have requested, verifying and improving the products and services we provide, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process sensitive personal information without the purpose of inferring characteristics about the relevant individual, and we do not sell sensitive personal information or process or otherwise share sensitive personal information for the purpose of targeted advertising.

For Residents of Delaware, Minnesota, and Oregon

The Right to a List of Third Parties

The right to request a list of the specific third parties (as defined under applicable law) to whom we disclose personal information. To exercise this right, please email us at support@bagelcode.com.

 

To Exercise Your Privacy Rights

 

To submit a request to exercise your right to access, deletion, or correction, please use “Your Privacy Request” link.

 

To exercise your right to opt-out of “sales,” “shares,” “targeted advertising,” or certain use/disclosure of “sensitive” personal information, please click our “Your Privacy Request” link (found in the website footer) and follow the instructions therein. As discussed in such link, you may also visit our website with the Global Privacy Control (GPC) signal enabled to opt-out of “sales/shares” via tracking technologies (learn more about GPC at www.globalprivacycontrol.org) and we will honor such choice as required under the State Privacy Laws. In either case, these opt-outs apply on the account level to the extent possible and also it can be controlled on the browser level for the device you use to opt out.

 

Unless otherwise prohibited by the State Privacy Laws, we may need to verify your identity and confirm your residency before processing your request. In order to verify your identity, we will generally either require the successful authentication of your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, or date of last transaction on our Service.

 

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we cannot comply with a request, we will explain the reasons in our response.

 

Non-Discrimination and Appeals

 

You have the right to not receive “discriminatory” treatment for exercising the rights discussed in the table above. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

 

Further, depending on your state of residency, you may have the right to appeal our decision not to take action on your rights request. All appeals should be submitted by emailing support@bagelcode.com, along with a copy of the decision that you are appealing.

 

Authorized Agents

 

In certain circumstances under the State Privacy Laws, you may be permitted to use an authorized agent to submit requests on your behalf (using the mechanisms for submitting requests above), where we can verify the authorized agent’s authority to act on your behalf.

 

For requests to access, delete, or correct personal information, we require the following for verification purposes:

 

·       a power of attorney from you or your authorized agent that is valid under the laws of the applicable state where you reside; or

·       sufficient evidence to show that you have:

o   provided the authorized agent signed permission to act on your behalf; and

o   verified your own identity directly with us or directly confirmed with us that you provided the authorized agent’s permission to submit the request on your behalf.

 

For requests to opt-out of “sales,” “shares,” or the processing of your personal information for “targeted advertising” under the State Privacy Laws, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

 

Automated decision-making

 

We may use automated decision-making technologies to support our data processing activities. Our automated decision-making capabilities include logic that provides special offers relevant to your usage. By using this logic, it helps us improve customer experience.

 

Deidentified Information

 

Where we process “deidentified information” (as such term is defined under the State Privacy Laws) and are required to keep such information deidentified, we commit to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process we used satisfies the requirements under applicable law.

 

Notice at Collection for California Residents

 

The following additional disclosures apply to California residents.

·       Categories/Use of personal information: In the last 12 months, we have collected the categories of personal information listed below. Further, please see “ADDITIONAL USES OF PERSONAL INFORMATION” for the purposes for which such personal information is used.

• Identifiers, such as your name, email address, date of birth, online identifiers, or other similar identifiers.
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birth date, contact information, and payment information.
• Protected Classification Characteristics, such as age and gender.
• Commercial Information, such as payment and purchase history.
• Internet/Network Information, such as device information, logs, and analytics data.
• Geolocation Data, such as location information from your device or generated based on IP address or Wi-Fi.
• Other Personal Information, such as information you post on our social media pages or otherwise provide to us.
• Inferences, such as predictions about your interests and preferences.
• Sensitive Personal Information, such as account username and password, and non-recipient message content.

 

“Sales” and “Shares”: We may disclose all of the categories of personal information we collect to the categories of recipients set forth in the OUR DISCLOSURE OF PERSONAL INFORMATION section of our Privacy Policy. Our disclosure of personal information to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal information for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services) under certain privacy laws: Advertisement Partners and Third-Party Partners.

 

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising. To submit a request to not to sell or share your personal information, please use this form “Your Privacy Request” link.

 

 

 

 

 

 

ADDITIONAL EEA, UK AND SWISS DISCLOSURES

 

These disclosures supplement the information contained in our Privacy Policy by providing additional information about our personal information processing practices relating to individuals who access and use our website or services or otherwise interact with us from the EEA, UK and Switzerland.

 

Questions or Complaints

 

If you have a concern about our processing of personal information, you have the right to lodge a complaint with the Data Protection Authority where you reside, where you work, or where an alleged violation of the law has occurred. Contact details for applicable Data Protection Authorities can be found using the links below:

• European Economic Area: https://edpb.europa.eu/about-edpb/board/members_en
• United Kingdom: https://ico.org.uk/global/contact-us/
• Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

 

We would, however, appreciate the chance to handle your concerns directly prior to a complaint being filed, so please contact us directly at support@bagelcode.com if you have any concerns.

 

Purposes and Legal Bases of Processing

 

When we process your personal information, we will do so in reliance on the following lawful bases. You are not required to provide personal information to us, but we do rely on your personal information to provide certain of our products and services. If you choose not to provide us with your personal information, we may not be able to provide you with a service or product you request. We will inform you at the point that we collect personal information from you if the provision of certain personal information is mandatory or optional for receipt of our products and services.

 

We use personal information that you submit directly to us, that we collect automatically or that we collect from third parties, when you access our website, contact us or use the services, as follows:

 

Personal Information You Provide When You Use the Services

 

How we use Personal Information	Categories of Personal Information used	Lawful basis
To communicate with you about our services (including sending you notifications and alerts)	Contact information and identifiers	Performance of a contract with you
To send your direct marketing in accordance with your preferences, including relating to competitions and sweepstakes	Contact information and identifiers	Your consent
To provide you customer support in connection with your use of the Services	Contact information and identifiers  Account information Your communications with us	Performance of a contract with you
To set up and authenticate your account on the services	Account information	Performance of a contract with you
To confirm you are eligible to use the Services	Profile information	Where we are required by law to verify your age to participate in the Services, our legal obligations. Otherwise, our legitimate interests, namely to ensure that the Services remain age-appropriate in accordance with our policies
To provide you with Services, including social and chat features	Account information Profile information and gameplay Your interactions with social and chat features	Performance of a contract with you
To display your rankings, high scores and profile information to other users, in connection with the Services	Profile information and gameplay	Performance of a contract with you
To facilitate payments made on the Services, at your request	Contact information and identifiers  Account information Transaction related information for purchases	Performance of a contract with you
To conduct internal auditing and for our own internal record-keeping purposes	Contact information and identifiers  Account information Transaction related information for purchases	Our legitimate interests, namely to preserve relevant records for the function of our business
To protect our property and enforce our rights	Contact information and identifiers  Account information Transaction related information for purchases	Our legitimate interests, namely to protect and enforce our rights for the benefit of Bagelcode, its staff, users and partners
To collect your feedback to improve the Service and develop new products and services	Contact information and identifiers  Account information Survey information Your communications with us	Our legitimate interests, namely informing our service development and improvement
To provide and administer your participation in sweepstakes, competitions, and events (e.g VIP promotions)	Contact information and identifiers  Account information Participation in competitions and sweepstakes	Performance of a contract with you
To use in our marketing materials	Profile information and gameplay Participation in competitions and sweepstakes	Our legitimate interests, namely marketing our services to individuals

 

Personal Information We Collect From Third Parties

 

How we use Personal Information	Categories of Personal Information used	Lawful basis
To authenticate you to Social Games	Social Network Login Information	Performance of a contract with you
To provide you with Social Games, including social and chat features	Social Network Identifiers and Profile Information Social Network Invites and Interactions	Performance of a contract with you
To conduct internal auditing and for our own internal record-keeping purposes	Transaction information related to your purchases, as received from Payment Services or Third Party Platforms with in-app Purchasing Services	Our legitimate interests, namely to preserve relevant records for the function of our business
To protect our property and enforce our rights	Transaction information related to your purchases, as received from Payment Services or Third Party Platforms with in-app Purchasing Services	Our legitimate interests, namely to protect and enforce our rights for the benefit of Bagelcode, its staff, users and partners
To suggest products and services that may be of interest to you	Information about your internet usage over time and inferences about you, as received from Business Partners (i.e. our advertising partners)	Your consent
To tailor our advertising that we send to you, in accordance with your preferences	Social Network Identifiers and Profile Information Social Network Invites and Interactions Information about your internet usage over time and inferences about you, as received from Business Partners (i.e. our advertising partners)	Your consent

 

Personal Information We Generate About You

 

How we use Personal Information	Categories of Personal Information used	Lawful basis
To suggest products and services that may be of interest to you	Inferences	Your consent

 

Personal Information We Collect Automatically

 

How we use Personal Information	Categories of Personal Information used	Lawful basis
To present the Services to you on your device.	Device Data Approximate Location Data	Performance of a contract with you
To conduct research, analytics and development to improve the Service and develop new products and services	Analytics and Usage Data Approximate Location Data	Your consent
To identify potential risk of unlawful behaviour, including identifying and preventing fraud or malicious use of our Services.	Device Data Analytics and Usage Data Approximate Location Data	Our legitimate interests, namely ensuring the security and integrity of our systems for the benefit of Bagelcode, and its users
To tailor how the Services are provided to you, including personalising the Services in accordance with your preferences.	Device Data Approximate Location Data	Where we adjust the Services in accordance with preferences that you set, the processing is necessary for the performance of a contract with you.   Otherwise, your consent.
To monitor the performance of, identify errors in, and improve the Services, including measuring traffic and usage trends for the Services.	Analytics and Usage Data	Your consent
To tailor our advertising that we send to you, in accordance with your preferences	Analytics and Usage Data	Your consent

 

International Transfers of Personal Information

 

We operate and engage third-party partners and providers in various jurisdictions. Therefore, we and our third-party providers may transfer personal information to, or store, access, or process personal information in, a country other than the one in which it was collected, including, but not limited to, the United States. The country to which personal information is transferred may not provide the same level of protection for personal information as the country from which it was transferred.

 

We may transfer personal information about you outside of the EEA, UK, and Switzerland, and when we do so we rely on appropriate or suitable safeguards recognized under applicable law, including adequacy decisions, standard contractual clauses, and the DPF (defined below). If you would like more information on the specific safeguards we use (and to obtain a copy of such safeguards, where applicable), please contact us at support@bagelcode.com.

 

Adequacy Decisions

 

We may transfer personal information about you to countries that the relevant regulatory authority has deemed to adequately safeguard personal information, either automatically or in connection with a specific safe harbor framework.

 

Standard Contractual Clauses

 

Certain regulatory authorities have adopted standard contractual clauses, which provide safeguards for personal information transferred outside of the originating jurisdiction. We may use these standard contractual clauses when transferring personal information to a third country that has not been deemed to adequately safeguard personal information.

 

Data Privacy Framework

 

The EU-U.S., Swiss-U.S. Data Privacy Framework and UK Extension (“DPF”) was designed by the U.S. Department of Commerce and the European Commission (and respectively the Swiss Council and UK Secretary of State) to ensure adequate protection for personal information transferred to a company participating in the DPF. If we transfer any personal information about you from the EEA, UK or Switzerland to a third party outside the EEA, UK or Switzerland who is participating in the DPF, we may rely on their participation in the DPF to ensure adequate protection for personal information so transferred.

 

We may transfer your personal information to, or store your personal information in, the following countries:

 

Country	Appropriate Safeguard
United States of America	Standard Contractual Clauses adopted by the European Commission / regulation of the UK Secretary of State or Swiss Council Sharing with recipients certified to the DPF
Republic of Korea	Adequacy, Standard Contractual Clauses adopted by the Swiss Council
EEA	If you are in the UK or Switzerland, Adequacy
UK	If you are in the EEA or Switzerland, Adequacy
Switzerland	If you are in the UK or EEA, Adequacy

 

Online Advertising

 

We work with online advertising networks, social media companies and advertising partners to tailor the ads played or displayed to you on other websites, apps, or services. The ads you see online are tailored to your interests based on information collected about you, including information about your age, demographic, location, as well information about your internet usage over time, such as the websites you visit, the products and pages you view and the links you click on (including links in ads played or displayed to you).

Typically, this information is collected through cookies, mobile software development kits or similar tracking technologies. When you use the Services, we will, if you give us your consent to do so, place cookies and similar tracking technologies on your device to:

·       identify you and your device, and share this information with the relevant advertising networks, so that they can serve you advertising based on the information those advertising networks (or the partners they work with) have about your internet usage history;

·       collect information about how you use the Services, so that when you visit another website or application that works with the same advertising network as us, we can play you adverts for Bagelcode which are tailored to the products and services you have previously viewed; and

·       identify whether your visit to the Services or a purchase of our products through the Services was related to an advert shown to you on another website or on your social media account.

 

Please see the “Purposes and Legal Bases of Processing” section of these Additional UK, EEA and Swiss Disclosures, for details of the information collected about your use of the Services for advertising purposes.

 

We will only collect and share information about your use of the Services for advertising purposes to the extent you have given us your consent to do so. Please refer to the “Your Additional EEA, UK, and Swiss Privacy Request” section of these Additional UK, EEA and Swiss Disclosures, for details of how you can manage your preferences.

·       withholding or withdrawing consent will mean that information about your use of the Services:

·       will not be shared with advertising networks to allow us to target advertising on other websites;

·       will not be used by us to tailor advertising on social media; and

·       will not be used to measure the effectiveness of our advertising campaigns by attributing purchases or visits to particular advertising partners, networks or social media.

 

You will still get ads when you browse the internet or social media, and those ads may still be relevant to your interests. However, this will be based on target audiences (i.e., individuals sharing certain characteristics) rather than targeting based on your actual online activity. As a result, you may see advertising targeted to your location, demographic or other information in your social media profile or the websites you visit even if you reject cookies on the Services.

Your Additional EEA, UK, and Swiss Privacy Request

 

Subject to certain limitations at law, you may be able to exercise the following rights: 

• Right to Access: The right to obtain confirmation of whether we are processing personal information about you, access to and a copy of the personal information we are processing about you, and information relating to its processing, including:
• The categories of personal information being processed;
• The purposes of the processing;
• The categories of the sources of the personal information;
• The categories of recipients to whom the personal information have been or will be disclosed;
• The envisaged period for which the personal information will be stored, or the criteria used to determine that period;
• Any automated decision-making or profiling performed in connection with your personal information; and
• The safeguards relied upon for the transfer of personal information to any third country.
• Right of Portability: The right to obtain a copy of the personal information we have collected about you in a structured, commonly used, and machine-readable format, and the right to transmit that personal information to another controller without hindrance.
• Right to Rectification: The right to correct or update any personal information about you that is inaccurate or incomplete.
• Right to Restriction of Processing: The right to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

Right to Object to Processing: The right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

 

• Right to Withdraw Consent: The right to withdraw your previously provided consent to our processing of your personal information. Please note withdrawing your consent will not affect the lawfulness of our use of your personal information before your consent was withdrawn, nor our processing of personal information pursuant to a different lawful basis for processing.
• Right to Erasure: The right to have us erase your personal information if the continued processing of that personal information is not otherwise justified.

 

Please note that if the exercise of these rights limits our ability to process personal information, we may not be able to provide our services to you, or otherwise engage with you in the same manner.

 

Submitting Privacy Rights Requests

 

Please submit a request specifying the right you wish to exercise by sending an email to support@bagelcode.com.

 

Before processing your request to exercise certain rights (taking into account the confidential nature of any personal information we maintain), we will need to verify your identity and confirm you are accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.

 

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity as needed to protect your personal information or locate your information in our systems, or where you are not accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland.

 

Direct Marketing Preferences

 

We will only send you marketing materials where we have your consent to do so. You can withdraw your consent to marketing materials by clicking on the unsubscribe link in the footer of our marketing emails or by contacting us at support@bagelcode.com. We make every effort to promptly process all unsubscribe requests. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to the features of the services, technical and security notices).

 

“Your Privacy Request” Link

 

Additionally, please see our “Your Privacy Request” link (found in the website footer) to exercise your opt-out rights accordingly, or to ask any other privacy related requests. You can also request opt out of all marketing emails through this request. 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.