Privacy Policy

Effective October 6th, 2024

Caelum Inc (“Caelum”) is committed to protecting the privacy of its users (“users” or “you”). In this Privacy Policy, “Caelum” refers to Caelum Inc, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We may also refer to Caelum as “we”, “us” or "data controller". This Privacy Policy has been created to inform you about how we, as the data controller of your personal data, manages, makes decision in relation to, collects, stores, uses and protects the personal data you provide. This Privacy Policy applies whenever you use our “Services,” which means our games and applications, products, services, content, websites operated by us. Also, this Privacy Policy describes how you can access and update that personal data.

By using the Services, you acknowledge the collection, disclosure, storage and use of your personal data as outlined in this Privacy Policy. If you do not want us to collect, store, use or share the personal data you provide in the ways described in this Privacy Policy, you should not play our games or use our Service.

Personal Data We Collect

Caelum's primary objective in collecting user information is to provide and enhance its Services, and to enable users to enjoy its Services. We may collect information about you directly from you and from third parties, as well as automatically through your use of our Websites, Applications or Services.

1. Information That You Provide Directly

When you use our Service (including through a social network), you may give us information directly in a number of ways, including: via social media, in communications with customer support, in response to surveys, Account creation and purchase of goods/services.

• your first and last name;
• your email address;
• information about your device on which you are playing one or more of our games;
• information about a request or inquiry you make;
• information you provide to help us improve our Service.

We also collect other information you provide to us and the content of messages you send to us, such as the feedback and product reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, may be recorded.

2. Information from Third Party Service

We may collect or receive information about you from other sources like third-party applications, such as an app store (e.g. Google, Apple, Amazon), third party login service, and social networks that you choose to connect or interact with through our services. For example, when you connect with Facebook in our games and services, we receive your username, profile picture and information, and friends list.

If you play our games or access our Service on connected third-party applications or connect our Service to any third-party applications, including social networks like Facebook, we may receive certain information about you from the provider of the third-party application. For information about how third-party applications (like Google, Apple, Facebook, etc) may disclose your information, please consult the third-party applications' Privacy Policy. We have no control over how third-party applications use or disclose the personal data you provide to it. We store the information that we receive from third-party applications along with other information that we collect from you or receive about you.

The information collected from the third-party application may include:

• your username;
• your profile picture or its URL;
• your email address you provided to the third-party application;
• your social network or third party service user identification number (like your Facebook ID number);
• your friends list, which includes the user ID number and other information of your friends, like their names and profile photos;
• your purchase of a virtual product of any type. Please note that because a third party site manages the purchases of virtual goods offered by the Services, we don't have access to your credit card details or any other billing information.

3. Information from You Playing Our Games

We may collect information about your use of our Services both in the course of game play and software usage, which may include but is not limited to:

• your device’s unique identifier;
• the type of your device;
• your device's model identifier;
• your device’s operating system and version;
• the platform type;
• your device language and region;
• your device time zone;
• transaction identifiers for purchases;
• in-game activity, including the date and time of activity.

How We Use Your Information

We use the personal information we collect for purposes described in this Privacy Policy, including to fulfill your specific requests, purchase orders, comply with law, and for other legitimate business purposes, such as:

• To provide and maintain our Services;
• To improve, and optimize our Service and our players’ experiences;
• To facilitate in-app purchases;
• To protect the safety and well-being of our players (including to prevent spam or fraud, stop cyber-attacks and to prevent illegal activities);
• To protect our legal rights;
• To provide customer support and respond to your questions;
• To send you information, including in-game updates, security alerts;
• To notify you of new products, content or promotional offers.

How We Disclose Your Information

We may disclose personal information with your consent or as we determine necessary to complete your transactions or provide the services you have requested or authorized.

In addition, we may share information (which may include personal data) with third parties, or allow third parties to collect information from our Services described below:

• Friends and other players: Some of your profile information can be seen by other players in the game, this includes your profile name (either the default name or a name that profile name of your choosing), your profile image (the default image, an image you select, or the profile photo associated with a linked account), the level of the game you are playing, and the amount of virtual items you have. You may select options available to edit your name and/or username, change your profile picture, and certain other information.
• Third-Party Advertising Servers: We work with third-party ad servers to display advertisements, provide us with performance reports, manage ad responses, analyze site usage, and help deliver relevant marketing messages and ads. These entities may use their own cookies and tracking technologies to collect information about your interactions with our app and other websites or apps you visit. This data is used for the purpose of analyzing and serving anonymous targeted advertising, which helps us deliver ads that are more relevant to your interests.
• Monetization Partners: We may share your Personal Data with our monetization partners, including but not limited to Google, Google AdMob, Facebook, Meta, Unity Ads, ironSource Ads, Liftoff Monetize, Vungle, and AppsFlyer. These partners use this information to optimize ad delivery, improve ad targeting, and maximize revenue generation. They may also use the data to conduct analytics and performance tracking across different platforms.
• SDKs: We integrate Software Development Kits (SDKs) provided by third-party vendors into our platform. These SDKs collect and transmit data necessary for various services such as analytics, advertising, or payment processing. The information collected may include user behavior, device details, and interaction data, which are used to enhance service functionality and user experience.
• Endpoints: your data may be securely transmitted to and from our servers through secure communication endpoints. These endpoints include services like vungle, unity3d, gstatic, googlevideo, googleusercontent, googletagservice, googlesyndication, googleapis, fbsbx, facdn, facebook, doubleclick,appsflyersdk etc. The secure transmission ensures data integrity and privacy as we interact with our partners' systems.

GDPR Rights for EU Residents

If you are a resident of the European Union (EU), you have certain rights under the General Data Protection Regulation (GDPR):

• Right to Access: You have the right to request access to the personal information we hold about you and to obtain a copy of that information.
• Right to Rectification: You have the right to request that we correct or update any inaccurate or incomplete personal information.
• Right to Erasure: You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent on which the processing is based.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information under certain circumstances, such as when you contest the accuracy of the information or when you object to the processing.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another data controller.
• Right to Object: You have the right to object to the processing of your personal information on grounds related to your particular situation, including processing for direct marketing purposes.
• Rights Related to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.
• Right to Complain: You have the right to complain to a supervisory authority about our collection and use of your personal data.

To exercise any of these rights, please contact us at support@caelumart.com. We will respond to your request in accordance with the GDPR requirements.

California Consumer Privacy Act (CCPA)

If you are a resident of California, the CCPA grants you the following rights regarding your personal information:

• Right to Non-Discrimination: You have the right to not be discriminated against for exercising any of your CCPA rights.
• Right to Opt-Out: You have a right to opt out from future sales or sharing of personal information as those terms are defined by the CCPA.
• Right to Delete: You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions.
• Right to Know: You have the right to request details about the personal information we collect, use, disclose, and sell, if applicable.

To exercise any of these rights, please contact us at support@caelumart.com. We will respond to your request in accordance with the GDPR requirements.

Virginia Consumer Data Protection Act (VCDPA) Rights

If you are a resident of Virginia, the VCDPA provides you with the following rights:

• Right to Access: You have the right to request access to the personal information we hold about you.
• Right to Correct: You have the right to request the correction of inaccurate or incomplete personal information.
• Right to Delete: You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected or if you withdraw your consent.
• Right to Data Portability: You have the right to request a copy of your personal information in a portable and readily usable format.
• Right to Opt-Out: You have the right to opt out of target advertising, opt out of the sale of your personal data, and/or profiling that supports decisions that produce legal or similarly significant consequences for you.

Opting Out of Third-Party Targeted Advertising - To opt out from or otherwise control targeted advertising, you can access at: United States: NAI (http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/); Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/); Europe: European Digital Advertising Alliance (http://www.youronlinechoices.com/). In addition, if you do not want to receive third-party targeted ads, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the advertising identifier (like an IDFA) from your device’s Settings, which will prevent continued use of existing behavioral data tied to the previous advertising identifier.

Opting Out of the sale of your data and/or profiling - Note that the VCDPA defines “sell” and “personal data” , "profiling" very broadly, and some of our data sharing described in this Privacy Policy may be considered a “sale” under those definitions. To opt-out from “sales” or “sharing” of personal data, and/or profiling, please email your request to support@caelumart.com.

• Right to Appeal: If we deny your request to exercise any of these rights, you have the right to appeal our decision.

To exercise any of these rights or to appeal a decision, please contact us at support@caelumart.com. We will respond to your request or appeal in accordance with the VCDPA requirements.

Rights of Residents in Brazil under LGPD

If you are a resident of Brazil, the General Data Protection Law (LGPD) grants you the following rights:

• Right to Access: You have the right to request access to the personal information we hold about you and to obtain a copy of that information.
• Right to Rectification: You have the right to request the correction or update of inaccurate or incomplete personal information.
• Right to Erasure: You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected or if you withdraw your consent on which the processing is based.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information under certain circumstances.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another data controller.
• Right to Object: You have the right to object to the processing of your personal information on grounds related to your particular situation, including processing for direct marketing purposes.
• Right to Review Automated Decisions: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.

To exercise any of these rights, please contact us at support@caelumart.com. We will respond to your request in accordance with the LGPD requirements.

Data Deletion

If you want to request to review, delete, or change the information we have about you; request that we no longer make active use of your information; or if you have additional questions, please send an email to us at support@caelumart.com. We may need you to provide some personal information so that we may verify your request and locate your personal information to fulfill your request.

Children’s Privacy

Our Services does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us at support@caelumart.com. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Data Retention

We retain personal information for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes.

Data Security

We take reasonable steps designed to protect personal data; however, no system or network can be guaranteed to be 100% secure and therefore we cannot guarantee the security of data. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure.

Updates

We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. Each time you use our Services, the current version of the Privacy Policy will apply. If we make material changes to this Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law.

Contact Us

If you have any questions, comments or concerns about our Privacy Policy, please contact our Data Protection Officer (DPO) at support@caelumart.com. For all other matters, please contact our in-game customer support.