LEGAL DOCUMENTS

Terms of Service

MODIFIED ON: October 1, 2022

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English

1. INTRODUCTION
2. LIMITED LICENSE
3. OWNERSHIP
4. USER CONTENT
5. FEES AND PURCHASE TERMS
6. UPDATES TO OUR SERVICES
7. DISCLAIMER OF WARRANTIES
8. LIMITATION OF LIABILITY AND INDEMNIFICATION
9. DISPUTE RESOLUTION, GOVERNING LAW
10. GENERAL PROVISIONS


Please read these Terms carefully before using or accessing our Services.


1. INTRODUCTION

These Terms of Service (“Terms of Service,” “Terms,” or “ToS”) govern the relationship between you and Scopely, Inc. (together with its parents, subsidiaries, representatives, affiliates, officers, and directors, “Scopely” or “we” or “us”) regarding your access to and use of Scopely’s games, mobile apps, websites, content, products, and any related services (collectively the “Services” as further defined in Section 3).

In the event you are playing any of the following applications: TIKI SOLITAIRE TRIPEAKS, BINGO BASH, GSN CASINO, and GSN GRAND CASINO, these Terms govern the relationship between you and GSN Games, Inc., a wholly owned subsidiary of Scopely, regarding your access to and use of such related Services.

When you use or access our Services in any capacity, you represent that you are at least the minimum age to consent for data processing under the laws of your jurisdiction (e.g., 13 years old in the United States, and 16 in some EU territories), and not barred from accessing the Services under applicable law. Notwithstanding the foregoing, we may provide some Services that are available specifically to younger players as permitted under applicable law. Regardless, if you are under the age of 18, you hereby agree that you have gotten permission from a parent or guardian to use our Services, and your parent or guardian must agree to these Terms and accept them on your behalf. Parents and legal guardians are responsible for the acts of their children when they use our Services. If you access our Services through a third-party platform or site, you may be required to comply with their policies in addition to these Terms.

Our collection and use of personal information in connection with the Services is described in our privacy policies, which are hereby incorporated by reference into these Terms. The Privacy Policy for TIKI SOLITAIRE TRIPEAKS, BINGO BASH, GSN CASINO, and GSN GRAND CASINO as well as STUMBLE GUYS can be found here: www.scopely.com/privacyQ42022. The Privacy Policy for all other Scopely applications can be found here: www.scopely.com/privacy.

We may amend these Terms by posting the amended versions on our website or in the supplemental terms of the applicable Service(s). By continuing to access or use our Services after we post amended versions, you confirm your agreement to the Terms, as amended. If you do not agree with any of the changes, you must immediately stop accessing our Services, and your license to use our Services will immediately terminate.

This is a legally binding agreement, and you should read it carefully. By installing, using, or otherwise accessing our Services, you confirm your agreement to be bound by these Terms. If you do not agree with any of these terms, you may not install, use, or otherwise access our Services. Use of the Services is void where prohibited.

IMPORTANT NOTICE: For U.S. and Canadian players, disputes with Scopely must generally be resolved on an individual basis through final and binding arbitration. For more details, see the Arbitration Agreement in Section 9.

If there is any difference between the English version and any other language version of these Terms, the English version will apply (to the extent of the difference and to the extent permitted by applicable law).


2. LIMITED LICENSE

Limited License
Subject to your agreement and your continued compliance with these Terms and all relevant Scopely policies, we grant you a non-exclusive, non-transferable, non-sublicensable, revocable license subject to the limitations below to access and use our Services for your own personal (i.e., non-commercial) entertainment purposes. You agree not to use our Services for any other purpose. You also agree to comply with all applicable laws when accessing or using the Services. Any rights not expressly granted herein are reserved by Scopely and its licensors.

Any use of the Services in violation of the license restrictions contained in this Section 2 is strictly prohibited. To the fullest extent applicable under law, we reserve the right to determine whether one’s conduct violates these Terms, and to take any action we deem appropriate in accordance with these Terms, including but not limited to removing objectionable content and/or suspending or terminating access to the Services or any portion thereof.

Restrictions

You specifically agree to the following license restrictions in connection with the Services:

  • If you are under the age of 18, or under the age of legal majority in your jurisdiction, you may not access or use our Services without permission from a parent or legal guardian.

  • If you have been previously banned from accessing our Services, you are prohibited from re-accessing the Services.

  • You are prohibited from using our Services for commercial purposes.

  • You are prohibited from using our Services to advertise, solicit, or transmit any commercial advertisements, which include but are not limited to chain letters, junk, spam, or repetitive messaging (whether targeted or not targeted).

  • You are prohibited from creating an Account on someone else’s behalf.

  • You are prohibited from creating an Account using inaccurate or false information.

  • You are prohibited from renting, selling, gifting, or giving away your Account or Account-related information.

  • You are prohibited from selling or transferring prizes or rewards obtained in connection with the Services to any other person or entity.


You further agree that under no circumstance will you:

  • Engage in acts that are inappropriate and/or in conflict with the spirit or intent of the Services or these Terms.

  • Attempt to gain unauthorized access to, circumvent, modify, disrupt, overburden, or otherwise impair any aspect of our Services (including Accounts of others) or related technology, devices, systems, or networks.

  • Engage in unlawful, abusive, threatening, obscene, defamatory, libelous, harassing, hateful, violent, racist, or otherwise objectionable or offensive acts, whether by posting and/or transmitting such information through our Services, or by any other means (e.g., by posting links to such content).

  • Engage in acts or attempts to abuse, threaten, harm, harass, or advocate or incite harassment and/or violence towards another person, group, our employee(s), or our Services, or engage in any acts in violation of other publicly posted Scopely policies (e.g. our forum rules).

  • Use our Services to post, supply or make available any material or information that infringes on any copyright, trademark, patent, trade secret, right of privacy, right of publicity, or any other right of a person or entity.

  • Use our Services to post, display, or transmit any other person or entity’s private information, including personally identifiable and/or financial information.

  • Copy or reproduce (except as expressly permitted), translate, reverse engineer, derive source code from, modify, disassemble, decompile, or create derivative works based on or related to the Services.

  • Scrape, harvest, or otherwise extract data from the Services.

  • Seek to obtain advantage or information from our Services using methods not expressly permitted by Scopely.

  • Engage in solicitation or attempted solicitation of personal information from other users of our Services.

  • Institute, engage in, assist with, or become involved in any form of attacks upon our Services, including but not limited to denial of service attacks, creation or distribution of viruses or malware, or attempts to disrupt our Services or others’ enjoyment of our Services.

  • Create, use, offer, promote, advertise, make available, and/or distribute exploits, cheats, bots, software, hacks, mods or any unauthorized third-party code or software that can be used to interfere with, alter or modify our Services, or that can be used in conjunction with our Services.

  • Impersonate another person, including without limitation any other user or any Scopely employee.
    Use our Services to violate any applicable law or regulation.

  • Use our Services for any activities other than what are reasonably considered the common and usual activities associated with the Services for general entertainment.

  • Encourage anyone to engage in the foregoing.


Access or Use of the Services Associated With Your Account

When you access or use the Services, you create an account with us (an “Account”). In some cases, you may be asked to provide a username and password (collectively known as “Login Information”). You are responsible for all use of the Services and activity related to your Account, including all transactions and payments associated with that Account, which may include but are not limited to the use of your credit card and other payment systems such as PayPal. You agree to maintain accurate, complete, and up-to-date information in your Account, and our Privacy Policy describes how you can keep your personal information up-to-date. It is your sole responsibility to maintain the confidentiality of your Login Information and your unique player ID. You agree not to engage in any acts that may compromise the integrity, fair play and/or security of your Account, including but not limited to sharing Login Information or permitting unauthorized access, loss, or theft. If you learn or suspect that your Account has been compromised, please contact us immediately, and we also urge you to modify your Login Information to prevent further damage. To the fullest extent permitted under applicable law, we will not be responsible to you for any losses or harm you may suffer as a result of an unauthorized person accessing your Account and/or using your Login Information in connection with our Services.

As part of the Services, we offer you the opportunity to play with your friends or other matched opponents who generally align with your overall skill level in-game. These matched opponents may be auto-generated players that look and play like real people.

You are solely responsible for your interactions with other users of our Services and any other parties with whom you interact through the Services. We reserve the right but have no obligation, to become involved with any disputes related to those interactions. You agree to fully cooperate with us to investigate any suspected unlawful, fraudulent, or improper activity. If you have a dispute with any other user(s), you agree to release us from claims, demands and damages (actual and consequential) of every kind and nature, known and unknown, arising out of or related to such disputes to the fullest extent permitted under applicable law.

We reserve the right to reclaim and/or remove any usernames at our discretion at any time, for any reason. You may have only one Account per game on a properly supported device.

Suspension and Termination of Account and Services

Without limiting any other remedies and to the fullest extent permitted under applicable law, we may suspend, terminate, delete, limit, or modify Accounts or access to the Services or any portions thereof, hold, delay, or remove hosted content, take legal and technical steps to prevent access to the Services, or take other action consistent with these Terms, with or without notice to you, if we suspect or determine, in our sole discretion, that you have failed to comply with any of these Terms or have otherwise engaged in illegal activity or improper use of our Services. This may result in the loss or termination of your Account, information, persona, rankings, benefits, Virtual Items (as defined in Section 5 below), in-game purchases, or other losses. To the fullest extent permitted under applicable law, we are not and will not be held responsible for loss of any Account, information, persona, rankings, benefits, Virtual Items, in-game purchases, or other losses incurred, and are under no obligation to compensate you therefor.

We reserve the right to stop offering and/or supporting our Services or any portion thereof, including but not limited to any particular game, at any time for any reason, consistent with applicable law. If this occurs, your license to access or use the applicable Services will automatically terminate, and you may lose access to any content that you may have submitted or were in the process of submitting. We reserve the right in our reasonable discretion to terminate any Account that has been inactive for an extended period of time. Unless required by applicable law or app store policy, we are not required to notify you in advance of these actions, or to provide you any refunds, compensation, or any material or non-material benefit for discontinued or terminated Services or losses resulting therefrom.

You may choose to close your Account for any reason and at any time. If you choose to exercise this right, please inform Scopely that you wish to close your Account by either: (i) opening a help ticket directly in-game via the Help section for the applicable game and requesting that your Account be closed; or (ii) emailing [email protected] and requesting that your Account be closed. You understand that if you close your Account, you may no longer have access to information previously associated with your Account, including, without limitation, your game progress and any Virtual Items associated with your Account.


3. OWNERSHIP

The Services and all rights, title, and interest therein are and shall remain the property of Scopely or its licensors. This may include without limitation all games, mobile applications, software (including server software), websites, titles, characters, character names or profiles, stories, dialogue, animations, art, concepts, content, audio sounds and effects, musical compositions, visual effects, methods of operation, documentation, moral rights, in-game chat transcripts, all recordings of games and game play, and Virtual Items appearing and/or originating in our Services, whether provided, earned or purchased. Neither these Terms nor your use of the Services convey or grant to you any rights: (i) in or related to the Services, except for the limited license granted in the section “Limited License” above; or (ii) to use or reference Scopely or its licensors’ company name(s), logos, product and service names, or marks.

You acknowledge and agree that you will have no ownership or other property interest in any Account created in connection with the Services. You further acknowledge and agree that all interest in and rights to any such Account are and will be owned in perpetuity by and solely for the benefit of Scopely.


4. USER CONTENT

We may permit you or other users to submit, upload, publish, transmit, or otherwise make available to us materials, data, information, communications, pictures and sounds using the Services (“User Content”). Your User Content remains your property. However, once you make User Content available on the Services, you thereby grant to Scopely an irrevocable, perpetual, transferable, sublicensable, fully paid-up, royalty-free, worldwide right and license to copy, reproduce, fix, adapt, modify, create derivative works from, manufacture, commercialize, publish, distribute, sell, license, sublicense, transfer, lease, transmit, publicly display, publicly perform, provide access to electronically, broadcast, communicate to the public by telecommunication, display, perform, enter into computer memory, and use and practice, in any way, your User Content as well as all modified and derivative works thereof in connection with the Services, including marketing and promotion of the Services, without notice to or consent from you, and without compensation to you or any other person or entity. You further hereby grant to Scopely the unconditional, irrevocable right to use and exploit your name, likeness and any other information or material submitted or transmitted to Scopely in connection with any User Content, without any obligation to you. Except as prohibited by law, you waive any rights of attribution and/or any moral rights you may have in your User Content, regardless of whether User Content is altered or changed in any manner.

As a user, you are personally and solely responsible for all information you post and/or send, transmit, or provide to others in connection with our Services, including but not limited to User Content you post in forums, blogs, and player chat features. Please do not use these mediums to share or post information you wish to remain confidential. You represent, warrant, and affirm that your User Content is accurate, that it does not violate any applicable laws or rights of others, that you have the appropriate permissions or rights from any third parties whose information or intellectual property is comprised in the User Content, and that yourUser Content is free of malware, viruses, adware, spyware, or any malicious code. You agree not to submit and/or transmit any User Content that is unlawful, tortious, defamatory, libelous, obscene, threatening, harassing, abusive, violent, hateful, racist, or otherwise objectionable or inappropriate. We do not assume any liability or responsibility for any user behavior or for monitoring User Content or conduct in connection with the Services. We may, but are not obligated to review, monitor, reject, deny, or remove User Content, at our sole discretion and at any time and for any reason, without notice to you.

User Content may be processed by us in accordance with our Privacy Policy. Please contact us if you have questions regarding your User Content or Account by either: (i) opening a help ticket directly in-game via the Help section; or (ii) emailing us at [email protected].


5. FEES AND PURCHASE TERMS

Any time you purchase virtual currency (including but not limited to virtual cash and other in-game premium currency), virtual in-game items, and any other premium goods or services in connection with our Services (collectively, “Virtual Items”) with real currency (i.e., real world money), Scopely grants you a limited, personal, non-transferable, non-sublicensable, revocable license to use such Virtual Items. All purchases and redemptions of such Virtual Items through our Services are final and non-refundable, unless otherwise determined by us. Scopely may manage, regulate, control, modify, or eliminate Virtual Items at any time, with or without notice to you. Scopely will have no liability to you or any third party in the event that Scopely exercises any such rights.

Virtual Items have no real-world value. Other than as expressly authorized in our Services, you may not sell, redeem, or otherwise transfer Virtual Items to any person or entity, including but not limited to Scopely, another user, or any third party.

You understand that use of the Services may result in charges to you, and you agree to pay all fees and applicable taxes incurred by you or anyone using your Account. Payments will be enabled using the payment method associated with your Account. We may revise the pricing for the goods and services offered through our Services at any time. We may also from time to time provide certain users with offers and discounts that may result in different amounts charged for the same or similar services or goods obtained through the use of the Services, and you agree that such offers and discounts, unless also made available to you, shall have no bearing on your use of the Services or payments charged to your Account. If you choose to sign up for a subscription or VIP experience in connection with the Services, payments will be enabled in accordance with the terms displayed to you at the point of purchase, and available to you thereafter on the applicable Service(s). You acknowledge and agree that, except where otherwise provided under applicable law, we are under no obligation to provide you with a refund for any items (including Virtual Items) that are in your Account, for any reason, including but not limited to termination of your Account or when closing your Account, whether such actions are voluntary or involuntary.

If you choose to sign up for a subscription or VIP experience, you will be presented with subscription-specific terms at that time, describing if and when your subscription will automatically renew, for what period of time, and at what cost, and how to tell us to cancel it. Those terms will also explain how to cancel a subscription and the time period in which you should do so before you will be charged. Those terms will also be available to you after you sign up, including in-game through the Help settings.


6. UPDATES TO OUR SERVICES

You understand that our Service is a developing and evolving one. Scopely may require that you accept updates to our Services. While Scopely will make all reasonable efforts to inform you of any such updates, you acknowledge and agree that Scopely may update our Services, with or without informing or otherwise notifying you. You may need to update third-party software from time to time in order to receive our Services and/or play our games.


7. DISCLAIMER OF WARRANTIES

Without limiting Scopely’s liability under Section 8 below, the Services are provided on an “as is” and “as available” basis for your use, with no warranties of any kind, express or implied, including without limitation the warranties of merchantability, fitness for a particular purpose, title, non-infringement, and those arising from course of dealing or usage of trade. Scopely does not warrant that you will be able to access or use our Service at the times or locations of your choosing; that our Services will be of a certain quality or suitability, or will be uninterrupted or error-free; that defects will be corrected; or that our Services are free of viruses or other harmful components.


8. LIMITATION OF LIABILITY AND INDEMNIFICATION

Limitation of Liability

Scopely will not be liable to you for any indirect, incidental, consequential, special, exemplary, punitive or other similar damages, including but not limited to loss of revenues, lost profits, lost data or business interruption or other intangible losses (however such losses are qualified), arising out of or relating in any way to these Terms or our Services, whether based on contract, tort or any other legal theory, and whether or not Scopely has been advised of the possibility of such damages. Scopely will not be liable to you for more than the amount you have paid to Scopely in accordance with these Terms in the six (6) months immediately preceding the date on which you first assert a claim. You acknowledge and agree that if you have not paid anything to Scopely during such time period, your sole remedy (and Scopely’s exclusive liability) for any dispute with Scopely is to stop using the Services and to cancel your Account. Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of liability for certain types of damages. Accordingly, some of the above disclaimers and limitations may not apply to you.

To the extent that Scopely may not, as a matter of applicable law, disclaim any warranty or limit its liability as set forth herein, the scope of such warranty and the extent of Scopely’s liability will be the minimum permitted under such applicable law. In particular, nothing in these Terms will affect the statutory rights of any consumer or exclude or restrict any liability for death or personal injury arising from any negligence or fraud of Scopely. This provision shall have no effect on the choice of law provision set forth below.

Indemnification

You agree to indemnify, save, and hold Scopely, its affiliated companies, officers, directors, contractors, employees, agents, third-party suppliers, licensors, and partners harmless from any and all claims, losses, damages, and liabilities, including legal fees and expenses, arising out of or relating to: (i) your use or misuse of our Services or goods or services obtained in connection therewith; (ii) your breach or violation of these Terms; (iii) our use of your User Content; or (iv) any breach of the representations, warranties, and covenants made by you herein. We reserve the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify us, and you agree to cooperate with our defense of these claims. We will use reasonable efforts to notify you of any such matter upon becoming aware of it. You agree that the provisions in this paragraph will survive any termination of your Account(s) or of our Services.


9. DISPUTE RESOLUTION, GOVERNING LAW

Informal Dispute Resolution

If a dispute arises between you and us, we prefer amicable resolution to protracted legal battles. To that end, we have created an informal dispute resolution program we believe can resolve most matters. Before initiating any arbitration or court proceeding, you must first follow these steps:

  1. 1. CHECK THE FAQ: You can start your resolution process by reviewing our “Help/FAQ” section for the applicable game or Services. Each “FAQ” section is specific to each game, and addresses the most commonly asked questions or concerns players may have, so please start there.

  2. 2. IN-GAME SUPPORT: If our FAQs did not resolve the issue, please complete a help ticket in-game, and be sure to clearly state your issue in the ticket. All tickets are reviewed by our player care team, who will work with you to resolve the issue through the inbox message system in your Account. Please bear with us; we may need to research your issue to fully resolve the ticket, and this may require us to ask further questions and engage with you over several communications. Although most issues can be resolved in this way, certain issues may require further escalation, as reasonably determined by us.

  3. 3. ESCALATION: If you have followed the above steps, but you feel that the issue remains unresolved after our agents have stated that a matter is closed, please email us at [email protected] and include a reference to the help ticket and specific issue you believe is unresolved. Our player care leads will work with you further to resolve your issue. In some cases, we may address the issue remotely. In others, we may ask to speak with you directly and will arrange a mutual time to discuss your matter. If you provide us with your phone number for this purpose, it will not be used for other purposes.


Arbitration Agreement

- If your issue remains unresolved after you have exhausted our informal dispute resolution system above, you may seek to resolve it through binding arbitration as follows:

- If you are a resident of the US or Canada, you and Scopely agree to resolve any dispute arising out of or related to these Terms or our Services on an individual basis through final and binding arbitration, provided you have exhausted the dispute resolution steps above and the dispute remains unresolved. This agreement precludes you from bringing any class action against Scopely. This agreement applies to all kinds of claims under any legal theory, except those described in the Exceptions to Agreement to Arbitrate subsection. It also applies even after you stop using your Account or have deleted it.

An arbitration proceeding proceeds before a neutral arbitrator instead of a judge and jury, so we both agree to give up our right to a trial before a judge or jury. Arbitration proceedings have different rules than lawsuits in court. Arbitration is less formal, and provides limited opportunity to compel the other side to share information relevant to the dispute—a process called discovery. The arbitrator can award the same damages and relief on an individual basis that a court can award to an individual. But, if you or we do not like the arbitrator’s decision, the courts only have a limited ability to change the outcome of arbitration or make the arbitrator reconsider his or her decision. If we have a dispute about whether this agreement to arbitrate can be enforced or applies to our dispute, we all agree that the arbitrator will decide that too, rather than a court or other agency. Unless you and Scopely otherwise agree in writing, any arbitration will be conducted only on an individual basis and not in a class, collective, consolidated, or representative proceeding.

Exceptions to Agreement to Arbitrate

We all agree that we each still have the right to go to court to resolve disputes relating to:

  1. Your or Scopely’s intellectual property (for example, trademarks, trade dress, domain names, trade secrets, copyrights, or patents); or

  2. Claims that are not subject to arbitration as a matter of applicable law not preempted by federal law, and that are within the jurisdiction of the court where they are brought.


No Class Actions

We all agree that we can only bring claims against each other on an individual basis.

That means:

  • Neither you nor Scopely can bring a claim as a plaintiff or class member in a class, collective, consolidated, or representative action.

  • The arbitrator cannot combine more than one person’s claim into a single case, and cannot preside over any class, collective, consolidated, or representative arbitration proceeding (unless we both agree to change this).


The arbitrator’s decision or award in one person’s case can only impact the person who brought the claim, not other individuals, and cannot be used to decide other disputes with other users.

The Arbitration Process, Rules, and Governing Law

The American Arbitration Association (“AAA”) will run the arbitration between you and Scopely, in accordance with the AAA’s rules and procedures then in effect (including their Supplementary Procedures for Consumer-Related Disputes, if applicable) (“AAA Rules”), except as modified here. If something in these Terms is different than the AAA Rules, then we will follow these Terms instead. To review the AAA Rules or to start an arbitration proceeding, you can refer to AAA’s website (www.adr.org) or you can call AAA at 1-800-778-7879. If either of us decide to initiate arbitration, we agree to provide the other party with a written Demand for Arbitration as specified in the AAA Rules.

You get to choose whether the arbitration will take place in the county or province where you live or in Los Angeles, California. We could also hold the arbitration in some other place, but we both have to agree to that. We also agree that during the arbitration process, members of our team may still work with you to resolve your issue informally.

Either of us involved in the arbitration can ask the arbitrator to put his or her decision or award, or his or her reasons for the decision or award, in writing. Also, either of us can take the arbitrator’s decision or award to a court to confirm it or enter a judgment on it (i.e., make it the same as a court judgment). Sometimes you can ask a court to change an arbitrator’s decision or award, but those circumstances are limited.

Notwithstanding any choice of law or other provisions in these Terms, we all agree that the Federal Arbitration Act (including its procedural provisions) will be applied to determine whether the provisions in this Section 9 can be enforced and how they should be interpreted.


10. GENERAL PROVISIONS

Severability
You and Scopely agree that if any portion of these Terms is found unlawful or unenforceable, in whole or in part, that provision will be ineffective only to the extent of such finding in such jurisdiction, without affecting the validity or enforceability thereof in any other manner or jurisdiction and without affecting the remaining provisions of these Terms, which will be enforced to the fullest extent of the law.

Choice of Law
If you are a US resident, these Terms and our relationship will be governed by California law, without giving effect to its conflicts of laws principles, except as otherwise provided above. As described in Section 9, the Federal Arbitration Act will apply to arbitrable disputes. If you reside outside the US, these Terms and our relationship will be governed by English law, without giving effect to its conflicts of laws principles.

Assignment
Scopely may assign or delegate these Terms, in whole or in part, to any person or entity at any time with or without your approval. You may not assign and/or delegate any of the rights or obligations you have under the Terms unless you obtain Scopely’s prior written approval. Any such assignment and/or delegation without Scopely’s prior written approval is ineffective and in violation of these Terms.

Force Majeure
We will not be liable for any delay or failure to perform resulting from causes outside of our reasonable control, including without limitation any failure to perform hereunder due to unforeseen circumstances or causes such as acts of God, war, terrorism, riots, embargoes, acts of civil or military authorities, fires, floods, pandemic, accidents, strikes, or shortages of transportation facilities, fuel, energy, labor, or materials.

Claims of Copyright Infringement
The Digital Millennium Copyright Act of 1998 (the “DMCA”) provides recourse for copyright owners who believe their rights under US copyright law have been infringed. If you believe in good faith that materials hosted by us infringe your copyright (for example, materials posted by a user on one of our forums), you or your agent can send us a notice requesting that the material be removed or access to it blocked.

If you believe your copyright-protected work has been posted on the Services in a way that constitutes copyright infringement (please consult an attorney to better understand your rights and obligations under Section 512(c) of the Copyright Act and other laws), please contact our DMCA Agent with a notice containing the following information:

  • Reasonably sufficient details to enable us to identify the work claimed to be infringed (e.g., title, author, any registration or tracking number, URL) or, in the case of multiple works, a representative list of such works;

  • Reasonably sufficient details to enable us to identify and locate the material claimed to be infringing (e.g., a link to the page that contains the material);

  • Your name, address, telephone number, and, if available, email address;

  • A statement that you have a good faith belief that the use of the material identified above is not authorized by the copyright owner, its agent, or the law;

  • A written statement, under penalty of perjury, that the information in your notice is accurate and that you are authorized to act on behalf of the owner of the exclusive right that is alleged to be infringed; and

  • Your physical or electronic signature.




If you believe material that you have posted to the Services has been improperly taken down, you may file a written counter-notice with our DMCA Agent. Please include the following details:

  • Identification of the material that has been removed or to which access has been disabled and the location at which it appeared before it was removed or disabled;

  • A statement, under penalty of perjury, that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification;

  • Your name, address, telephone number, and, if available, email address;

  • A statement that you consent to the jurisdiction of the Federal District Court for the judicial district in which your address is located or, if your address is outside the US, for any judicial district in which Scopely may be found, and that you will accept service of process from the person who submitted a notice in compliance with Section (c)(1)(C) of the DMCA, as described above; and

  • Your physical or electronic signature.


DMCA notices must meet current statutory requirements imposed by the DMCA.
Please send DMCA notices to our DMCA Agent at the following address or by email to [email protected] (subject line “DMCA Communication”): DMCA Agent, Scopely, Inc., 3505 Hayden Ave., Culver City, CA 90232.

Please note that under Section 512(f) of the Copyright Act, any person who knowingly materially misrepresents that material or activity is infringing, or that material or activity was removed or disabled by mistake, may be subject to liability. Please also be advised that we enforce a policy of terminating the Accounts of repeat infringers (i.e., users who have made two or more postings for which we receive a notice of infringement).

Scopely’s DMCA Agent should be contacted only for the purposes set forth in this Section. NON-DMCA INQUIRIES DIRECTED TO SCOPELY’S DMCA AGENT WILL NOT BE ANSWERED. MISUSE OF THE DMCA PROCESS CAN SUBJECT YOU TO LIABILITY.

Supplemental Terms
Supplemental terms may apply to certain Services, such as forums, contests, or loyalty programs (including subscriptions or VIP experiences). Supplemental terms will be disclosed to you in connection with the applicable Service(s). Those supplemental terms are in addition to and shall be deemed a part of the Terms for purposes of the applicable Service(s), and your right to use such features is subject to those supplemental terms.

Entire Agreement
These Terms, including any additional policies and documents referenced in this agreement, are the entire agreement between you and Scopely. They supersede all prior understandings between you and Scopely, regardless of the medium (oral, written electronic) and practice (custom, policy, course of business, precedent) by which such understandings were communicated.

No Waiver
Any failure of Scopely to enforce any right or provision in these Terms shall not constitute a waiver or relinquishment of such right or provision unless acknowledged and agreed to by us in writing. The express waiver by Scopely of any provision, condition, or requirement of these Terms will not constitute a waiver of any future obligation to comply with such provision, condition, or requirement. Except as expressly and specifically set forth in these Terms, no representations, statements, consents, waivers, or other acts or omissions by Scopely will be deemed a modification of these Terms or legally binding, unless documented in physical writing, hand signed by both you and a duly appointed officer of Scopely.

Notices
We may give notice to you via: (i) postings on the Services; (ii) email, telephone, or text message to any email address or phone number connected with your Account; (iii) written communication sent by mail to any address connected with your Account. All notices given by you or required from you under these Terms must be in writing and addressed to: Scopely, Inc. Attn: Chief Legal Officer, 3505 Hayden Ave., Culver City, CA 90232. Any notices that you provide without compliance with this subsection will have no legal effect.

Privacy Policy

Modified on: October 1, 2022

Choose the Language
English

Contents

- About this Privacy Policy
- Information We May Collect and How We Collect It
- How We Use Information
- How We Disclose Information
- Interest-Based Advertising
- Your Rights and Choices
- Data Retention
- Security
- Use By Minors
- Additional Information for Residents of the EEA, United Kingdom, Switzerland, and Brazil
- Additional Information for Residents of California, Virginia, Connecticut, Utah, and Colorado
- Contact Us

About this Privacy Policy

This Scopely Privacy Policy (“Privacy Policy”) describes how and when we may collect, use, secure, and share information collected in connection with our games, mobile applications, websites, content, products, and any related services (collectively, the “Services”), and your choices regarding our processing of that information. For purposes of this Privacy Policy, “Scopely” (or “we” or “us”) refers to Scopely, Inc. and its parents, subsidiaries, representatives, affiliates, officers, and directors for websites and applications that link to this Privacy Policy or otherwise make it available to you.

Please read this Privacy Policy carefully. We may update it from time to time by posting a new version on scopely.com with an updated date (the “Effective Date”). If we make material changes, we will notify you, prior to the changes becoming effective, through the Services or by other means if you’ve provided us additional contact information (e.g., using the email address associated with your Account, as defined in our Terms of Service). Your continued use of the Services after the Effective Date will be an acknowledgement of our updated practices.

If there is any difference between the English version and any other language version of this Privacy Policy, the English version will apply (to the extent of the difference and to the extent permitted by applicable law).

Information We May Collect and How We Collect It

We may collect various types of information, including information you provide or make available to us directly, information collected from your devices (including on web and mobile), and information collected from other sources, like social networking sites and gaming partners. Some of this information may be considered “personal information” or “personal data” under applicable privacy or data protection laws.

Information You Provide

You may provide information directly to Scopely when you:


  • Use or access the Services, including when you create a Scopely Account (as defined in our Terms) or make in-app purchases;

  • Create a Scopely Account for logging in across multiple games or Services;

  • Connect with or access our Services using a third-party ID or log-in, such as an ID for a social networking site or gaming service;

  • Communicate with or contact others using our Services, including when you use chat, “invite a friend,” “email this page,” or use other similar features;

  • Contact us, including for customer or technical support;

  • Participate in Scopely offers, contests, or special events;

  • Subscribe to newsletters or sign up to hear about current or upcoming products; and/or

  • Complete surveys offered by us or on our behalf.

Depending on how you choose to use the Services, you may provide us with the following types of information:

  • Contact information such as your first and last name, username or handle, third-party service ID, email address, phone number, home address or shipping address, and other contact information;

  • Images such as your photo, avatar, or other image;

  • Biographic and Demographic information such as your date of birth, gender, and time zone.

  • Transaction information such as purchase or payment information; and/or

  • Other information such as chat records, friends’ names and contact information, and location information you choose to share (for example, when you connect with our Services through social features).

Information Collected or Generated When You Use our Services

When you access or use our Services, we collect information from and about you and the device(s) you use. This may include the following information:

  • IP address, unique device identifiers, advertising identifiers, device serial numbers, and similar identifiers;

  • Device information such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, mobile network information, and in some cases, browser type and version, Internet service provider, referring/exit pages and URLs, or clickstream information;

  • Approximate location inferred from IP address;

  • In-game purchase information; and/or

  • Game scores and achievements, and other information as reasonably required to offer and enhance our Services.

  • Inferences, such as those drawn from any of the personal information we collect, to better understand your preferences.

Information Collected Using Cookies and Similar Technologies

We and our partners use various tools to collect information when you visit our sites and Services, including cookies, pixels, software development kits, advertising identifiers, and other similar technologies. Some of these technologies store information in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and information is then stored on your computer or other device so the website or app can access information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, your search history, and content you have viewed.

Depending on the Services you use, we and our partners may also use these technologies to gather information about how you view and use our Services and content, and to connect your activity with other information we store about you. Some of these partners include:

  • Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other information), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

  • Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.

  • Game Analytics. For more information, please see Game Analytics’ privacy policy here: https://gameanalytics.com/privacy/.

The use of these technologies helps us serve you better by understanding what you're interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect information from your browser or device for advertising and measurement purposes using their own similar tools.

At any time, you can control the use of cookies by adjusting the settings on your browser. However, if you choose to disable some or all cookies, please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available through our Services. For information about how you can manage your cookie and similar technologies preferences, please review the section of this Privacy Policy titled "Interest-Based Advertising."

How We Use Information

We may use the information we collect for a number of business and commercial purposes, including to:

  • Perform internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing, and research;

  • Understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns), as well as offer discounts or personalized pricing in accordance with applicable law;

  • Maintain the safety, security, and integrity of our Services, for example by authenticating players and providing account security and fraud detection;

  • Send you news and/or marketing communications (by email, phone, or text) subject to your marketing preferences and choices, including information about Scopely or third-party offerings we think may be of interest to you;

  • Administer contests, surveys, and sweepstakes you enter, notify contest winners, and award prizes;

  • Fulfill a purchase or send you order confirmations or other requested product or Service information;

  • Facilitate your communication with friends and other players, and enable features that allow you to share information with other people (for example, if you choose to use friend invite features); and/or

  • Comply with legal requirements and/or investigate or address claims or disputes relating to your use of the Services.

We may use the information we collect for a number of business and commercial purposes, including to:

  • Perform internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing, and research;

  • Understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns), as well as offer discounts or personalized pricing in accordance with applicable law;

  • Maintain the safety, security, and integrity of our Services, for example by authenticating players and providing account security and fraud detection;

  • Send you news and/or marketing communications (by email, phone, or text) subject to your marketing preferences and choices, including information about Scopely or third-party offerings we think may be of interest to you;

  • Administer contests, surveys, and sweepstakes you enter, notify contest winners, and award prizes;

  • Fulfill a purchase or send you order confirmations or other requested product or Service information;

  • Facilitate your communication with friends and other players, and enable features that allow you to share information with other people (for example, if you choose to use friend invite features); and/or

  • Comply with legal requirements and/or investigate or address claims or disputes relating to your use of the Services.

How We Disclose Information

At Scopely, we are in the business of creating great games, not selling information. Subject to your legal rights, we may disclose the information we collect about you, and may enable you to share this information, with a variety of third parties in various ways, including:

  • With vendors, consultants, business partners, payment processors, and other third-party service providers as necessary to carry out work on our behalf and otherwise provide the Services;

  • With other players, to enable you to interact with them and to share gameplay-related information such as high scores and other leaderboard information;

  • With the general public, if you choose to share information when contributing content to our Services through a forum, blogs, social features, or the like;

  • Where you choose to take advantage of social sharing features or related tools that let you share games and other actions you take on our Services, with the public, social media platforms, and/or your social media friends or contacts;

  • With others who share your device, if you make your Account available to them through that device;

  • With other parties engaging in sponsorships and co-branded opportunities and promotions;

  • With specific third parties if we believe disclosure is required by applicable law, regulation, or legal process;

  • With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our terms or other policies, and/or are fraudulent or in violation of applicable law, or as we determine necessary to protect the rights, property, or safety of Scopely or others;

  • In connection with an actual or proposed merger, consolidation, restructuring, sale of company stock and/or assets or other corporate change, including during the course of any due diligence process; and/or

  • In an aggregated or pseudonymous form or otherwise in a form that cannot reasonably be used to identify you.

In some cases, we may enable you to access third-party products or services through our Services. Please note that those products or services are offered by people or companies not affiliated with or controlled by us, and we are not responsible for their actions, their terms, their use of information, or their products or services. If you submit your information to a third party, that third party’s treatment of your information is governed by their privacy policy, which may differ from this Privacy Policy and which we encourage you to review.

We also share information with your consent or at your direction. For example, we may share your personal information if you opt in to receiving information from Scopely’s business partners.

Interest-Based Advertising

We may share some of your information with certain third-party partners to make advertising more relevant, to measure its effectiveness, and to help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure you receive appropriate advertising and personalized experiences. These third-party advertising partners include, but are not limited to Meta, Google, AppLovin, LiveRamp, Criteo, Microsoft, and their partners. Click each partner’s name for more information regarding their privacy practices.

If you prefer to opt out of having your web viewing behavior used for interest-based advertising, you can learn how to do so by clicking here, or if located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, by clicking here. If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may also do so through your device settings such as (“Allow Apps to Request to Track” on iOS and “Opt Out of Ads Personalization” on Android). Please note that even if you disable personalized advertising, you may continue to receive ads that are not based on your preferences.

Links to Other Websites

The Services may contain links to, or advertisements concerning, other websites. Other websites may also reference, advertise, or link to Scopely. Scopely is not responsible for the privacy practices or the content of such other websites. You should check the applicable privacy policy of any website you access through the Services.

Your Rights and Choices

You may be able to access, modify, and/or correct certain personal and other information available to you in your Account or in-app. Depending on where you reside, you may have additional rights, including those listed below in the sections called “Additional Information for Residents of the EEA, United Kingdom, Switzerland, and Brazil” and “Additional Information for Residents of California, Virginia, Connecticut, Utah, and Colorado.”

How to Exercise Your Rights

To protect the privacy of your information, Scopely verifies your identity and processes rights requests through our in-game help ticket system. If you wish to exercise any of the rights described above, please follow the instructions below and do not delete the game until your request is fulfilled:

  • Open the Scopely game(s) for which you wish to exercise your rights;

  • Visit the game’s settings menu;

  • Select “Contact Us,” “Support,” “Help,” or equivalent option to submit a support ticket via the chat icon;

  • Follow the prompts as provided by the Support team; and

  • Choose the applicable request.

If you have trouble with any of the steps described above, you can contact [email protected] for help. We may contact you to confirm your choices and to ask for additional information as needed to verify your identity and process your request.

Communication Preferences

Email, phone, and text: In order to opt-out of email communications, please click the “unsubscribe” link at the bottom of the email or contact us at [email protected]. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth below in the “Contact Us” section.

Push Notifications: In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.

“Do Not Track” / “Global Privacy Control”

Do Not Track (“DNT”) is a privacy preference that players can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which you can learn more about at https://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if our site detects a GPC signal from your device, we will interpret it as a request to opt out of selling or sharing your personal information and to opt out of targeted advertising under applicable state law. We will also interpret it as a request to limit the sale or sharing of personal information for targeted advertising for residents of the European Economic Area, the UK, and Brazil.

Data Retention

We may retain your personal information for as long as you have an Account with us. Following the closure of your Account, we may retain personal information where required by law or where we have an ongoing legitimate business need to do so. For example, we may retain such information to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, enforcement of our contracts and terms, or for safety reasons (e.g., we may retain certain information about an Account to prevent that player from opening a new Account).

Your Rights and Choices

You may be able to access, modify, and/or correct certain personal and other information available to you in your Account or in-app. Depending on where you reside, you may have additional rights, including those listed below in the sections called “Additional Information for Residents of the EEA, United Kingdom, Switzerland, and Brazil” and “Additional Information for Residents of California, Virginia, Connecticut, Utah, and Colorado.”

How to Exercise Your Rights

To protect the privacy of your information, Scopely verifies your identity and processes rights requests through our in-game help ticket system. If you wish to exercise any of the rights described above, please follow the instructions below and do not delete the game until your request is fulfilled:


  • Open the Scopely game(s) for which you wish to exercise your rights;

  • Visit the game’s settings menu;

  • Select “Contact Us,” “Support,” “Help,” or equivalent option to submit a support ticket via the chat icon;

  • Follow the prompts as provided by the Support team; and

  • Choose the applicable request.


If you have trouble with any of the steps described above, you can contact [email protected] for help. We may contact you to confirm your choices and to ask for additional information as needed to verify your identity and process your request.

Communication Preferences

Email, phone, and text: In order to opt-out of email communications, please click the “unsubscribe” link at the bottom of the email or contact us at [email protected]. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth below in the “Contact Us” section.

Push Notifications: In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.

“Do Not Track” / “Global Privacy Control”

Do Not Track (“DNT”) is a privacy preference that players can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which you can learn more about at https://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if our site detects a GPC signal from your device, we will interpret it as a request to opt out of selling or sharing your personal information and to opt out of targeted advertising under applicable state law. We will also interpret it as a request to limit the sale or sharing of personal information for targeted advertising for residents of the European Economic Area, the UK, and Brazil.

Security

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and take steps to ensure only those at Scopely with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your personal information is no longer secure, please immediately contact us as set forth below in the “Contact Us” section.

Use By Minors

Our Services are designed for a general audience and require all players to be above the minimum age to consent for data processing (for example, 13 years old in the United States, and 16 years old in some parts of the EU) as a condition of access. An exception to this is our game STUMBLE GUYS, which allows younger players to play. As such, we take additional steps to limit access to certain features of STUMBLE GUYS based on players’ ages, and also limit the personal information collection and sharing of such younger players’ information to only what is necessary to support our internal operations.

If you are a parent or guardian of a minor, and believe that minor has uploaded personal information in connection with our Services without your consent, or if you wish to review information collected from your minor child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a minor has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and revert them to the underage experience, if applicable.

Additional Information for Residents of the EEA, United Kingdom, Switzerland, and Brazil

If you are a resident of a member country of the EEA, the United Kingdom, Switzerland, or Brazil, then in accordance with applicable law, you may have the following rights:

Access: to obtain confirmation regarding whether we process your personal information, and to and obtain a copy of the personal information we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player or person.)
Rectification or Correction: to correct your personal information where it is inaccurate, incomplete, or outdated.

Erasure (deletion): to request that Scopely delete your personal information, for example when it is no longer necessary to fulfill the purposes for which Scopely collected it. This right may be limited to the extent that Scopely is permitted or required by applicable law to retain your information. (Note that if you request deletion of your personal information, you may no longer be able to use or access the Services. If you share devices with someone else who uses the Services, that person may also lose game progress or related Account information and access. If you decide to use or access the Services again, Scopely may consider this a new Account and may collect personal information associated with that Account in accordance with this Privacy Policy.)

Restriction or objection to processing: to object to Scopely’s processing of your personal information, or request that Scopely restrict that processing. Because the information that Scopely collects is generally required to provide the Services to you, if you object to the processing of your personal information, this may have the same effect as requesting deletion of this information. This right may be limited to the extent that Scopely is permitted or required by applicable law to continue processing the information. (Note that if you object to the processing of your personal information, you and others who use your devices to access the Services may no longer be able to use or access the Services.)

Portability: to receive a copy of your personal information in a structured, commonly used, and machine-readable format so that you can transmit it elsewhere.

Request to be informed: to request information about third parties with which your personal information has been shared.

Request review: to review decisions taken exclusively based on automated processing if these decisions could affect your data subject rights.

To exercise these rights, please see “Your Rights and Choices” above.

In addition to the rights described above, if we have collected and processed certain types of personal information with your consent, you may withdraw that consent at any time in the manner described when you provided consent. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to then, nor will it affect any processing based on lawful grounds other than consent.

You may have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, contact your local data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.

Legal Basis for Processing Personal Information

If you are from the EEA, the United Kingdom, or Switzerland, our legal basis for collecting and using your personal information will depend on the type of information and the context in which we collect it. In general, we collect personal information from you only:

  • Where we have your consent to do so, such as before we use or share your information for advertising that is targeted based on your browsing history, online behavior, or other personal information that we or third parties may have collected about you. If you consent to our use of your personal information for any purpose, you have the right to withdraw consent at any time by contacting us, as explained above;

  • Where we need it to perform a contract with you;

  • Where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. We have a legitimate interest in processing your personal information, for example, for the following purposes:

    • - Product and Service development, management, delivery, and enhancement;
    - Fraud detection and prevention;
    - Network and system security;
    - General corporate operations;
    - Compliance with applicable foreign laws;
    - Communications regarding your purchases; and
    - Non-targeted marketing and advertising.

  • Where we have a legal obligation to collect personal information from you or may otherwise need it to protect your vital interests or those of another person.

    • If you have questions about the legal basis on which we collect and use your personal information, please contact us at [email protected].

    International data transfer

    Your personal information might be transferred to a country outside the EEA, the United Kingdom or Switzerland, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

    If we transfer personal information which originates in the EEA, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses or similar contractual safeguards, and, if necessary, the implementation of further technical and organizational measures.

    Additional Information for Residents of California, Virginia, Connecticut, Utah, and Colorado

    Information We Collect, Use, and Disclose

    All sources of personal information collected are noted in the “Information We May Collect and How We Collect It” section above and retained pursuant to “Data Retention” above. The purposes for our collection of this information are described in “How We Use Information” above.

    In the past 12 months, we have disclosed (or have enabled you to disclose) the following categories of personal information to third parties for business or commercial purposes:






    CATEGORYCATEGORIES OF PARTIES TO WHOM INFORMATION IS DISCLOSEDCATEGORIES OF THIRD PARTIES TO WHOM INFORMATION IS SOLD AND/OR SHARED
    Identifiers and contact information, including first and last name, email address, phone number, home address or shipping address, and your friends’ names and contact information.Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use) and payment processors. Affiliates for purposes of business operations and support.N/A
    Identifiers such as username or handle, third party service ID, IP address, unique device identifier, advertising identifier, device serial number.Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use) and payment processors.Affiliates for purposes of business operations and support.Other players in multiplayer games (username only).Analytics providers and advertising networks.
    Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream information.Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use).Affiliates for purposes of business operations and support.Analytics providers and advertising networks.
    Commercial information, such as information regarding in-game purchase payment method.Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.Affiliates for purposes of business operations and support.N/A
    Commercial information, such as information regarding in-game purchase events and value of purchases.Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use), payment processors, and business partners.Affiliates for purposes of business operations and support.Advertising networks.
    Demographic information, such as your gender, age, date of birth, and language.Visual information, such as your profile picture and the profile pictures of your friends or contacts.Vendors, such as cloud service providers (including cloud-based customer service and survey tools we use).Affiliates for purposes of business operations and support.Service providers that enable image functionality on our behalf.Affiliates for purposes of business operations and support. Other players, depending on your sharing preferences.N/A
    Visual information, such as your profile picture and the profile pictures of your friends or contacts.Service providers that enable image functionality on our behalf.Affiliates for purposes of business operations and support. Other players, depending on your sharing preferences.N/A
    Non-precise geolocation information.Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use) and payment processors.Affiliates for purposes of business operations and support.N/A
    Other information you may share if you use social features when accessing our Services, including the organizations, links, and other information included on your social profile page.Service providers, and other providers or partners that support our operational business purposes.Affiliates for purposes of business operations and support. Other players, depending on your sharing preferences.N/A
    Inferences derived from personal information listed above in this chart, such as your characteristics and preferences.Vendors, such as cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use) and payment processors.Affiliates for purposes of business operations and support.Analytics providers and advertising networks.

    Note that we do not have any knowledge of sales or sharing of personal information of minors (e.g., for the purpose of this section, under 16 years of age in California). While our Services may allow you to create an account, we do not otherwise use or disclose any sensitive personal information.

    Your Privacy Rights Under Applicable State Law

    Subject to applicable law, if you are a resident of California, Virginia, Connecticut, Utah, or Colorado, you may have the following rights:

    • To Know and Access: to obtain a copy of the specific pieces of personal information we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)

    • Deletion: to request that Scopely delete your personal information. This right may be limited to the extent that Scopely is permitted or required by applicable law to retain information. (Note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and that if you share devices with someone else who uses the Services, that person may lose game progress or related Account information and access. If you decide to use or access the Services again, Scopely may consider this a new Account, and may collect personal information associated with that Account in accordance with this Privacy Policy.)

    • Opt-Out of "Sale" and Certain Sharing Practices: depending on the site you are visiting or the app you are visiting and your relationship with us, you have the right to opt-out of certain information sharing practices with Third Parties who do not act as our Service Providers. In some states, like California, this information sharing may qualify as a “share” or a “sale,” while in other states, like Virginia, this information sharing may qualify as “targeted advertising” (collectively, “personalized advertising”). If you wish to opt-out of personalized advertising associated with our games, please visit the “Do Not Sell or Share My Personal Information” setting found in a game’s settings menu, or by contacting us as set forth below.

    • Correction: to request the correction of inaccurate personal information that we may have on file about you.

    • Obtain additional details regarding Scopely’s information practices: You may have the right to request disclosures regarding Scopely’s information practices. (Note that this information is generally available in this Privacy Policy).

    If you wish to exercise any of the rights described above, please follow the instructions in “Your Rights and Choices” above. We will not discriminate against you, in terms of price or services that we offer, if you submit any of the requests listed above.

    Verification and Appeal Process: We are required by law to take reasonable steps to verify your identity prior to responding to your request. Please note that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). Please do not delete our game until your request is fulfilled. If we are unable to process your request via our in-game help ticket system, we may verify your request by asking for information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us or with one of our games. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and as permitted by applicable law. Where required by applicable law, we will notify you if we reject your request, and notify you of the reasons we are unable to honor your request.

    If you are a resident of Colorado, Virginia, or Connecticut, you have the right to appeal a request we deny when we have verified your identity and still decline to honor your request. The process for that appeal will be sent to you separately if your request is denied.

    Authorized Agent: Californian players may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a Californian player to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the player, and have sufficient access to that player’s laptop, desktop, or mobile device to exercise that player’s right digitally. If you are an authorized agent trying to exercise rights on behalf of a Scopely player, then you can make a request on the player’s behalf by contacting us as set forth below in the “Contact Us” section with supporting verification information with proof that you have access to the player’s interface (including, for certain requests, written permission from the player) and proof of your own identity.

    Refer-a-Friend, Promotions, and Similar Incentive Programs: We may offer referral programs, promotions such as sweepstakes, or other incentivized information collection programs. We may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide personal information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) Alternatively, we may ask you to provide your personal information in exchange for a reward or participation in a promotion. These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your information to us depends on how you ultimately use our Services, whereas the value of the referred party’s information to us depends on whether the referred party ultimately uses our Services. Said value will be reflected in the incentive offered in connection with each program. You may withdraw from the incentives at any time. In order to withdraw from the financial incentive, please contact us at [email protected].

    Shine the Light Disclosure: California residents are entitled to ask us for a notice that identifies the categories of personal customer information that we share with our affiliates and/or third parties for marketing purposes, and provides contact information for such affiliates and/or third parties. If you are a California resident and would like this information, please submit a written request to us using the contact information below in the “Contact Us” section.

    Contact Us

    If you have questions or concerns about this Policy or our information practices, you can contact us by email at [email protected], or by postal mail at: Scopely, Inc., Attn: Legal Department, 3505 Hayden Avenue, Culver City, CA 90232. If we receive a formal written complaint from you, we will attempt to contact you directly to resolve your concerns.



    Player Community Guidelines

    MODIFIED ON: MAY 16, 2022.

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    English

    At Scopely, we don’t just make games - we are active players in them, and like other players, we have more fun when playing in an inclusive community.

    Behavior that disrupts another’s experience hurts everyone’s ability to play. By following our Player Community Guidelines, we can all work together to ensure that everyone in our games has a great experience for years to come.

    Our intention with creating Player Community Guidelines is to help educate players about how to be upstanding community members, give examples of positive and negative behaviors, and help our players find the best ways to play well together.

    Our 5 core guidelines are:

    PLAY RESPECTFULLY - RESPECT EACH OTHER

    Players should only be challenging each other in the game, not in chat. Your intention, the context, and the impact your words and actions have on other players all matter;

    Ways to play respectfully:

    - Communicate in a way that builds, rather than disrupts the community; we want to make a community that is comfortable coming back, rather than drive others away
    - Use respectful language, even when in competition
    - Focus on the impact of words on others, not just your intention behind them
    - Learn from what bothers others, not just what you would be bothered by

    Examples of disrespectful behavior:

    - Bullying or harassing another player
    - Repeatedly contacting someone who does not want to communicate
    - Using hate speech or slurs anywhere in the game
    - For example, racist, sexist, anti-LGBTQ+, religious intolerance, ableism (or targeting based on medical conditions), extreme political views, advocacy of hate organizations, and xenophobic statements
    - Using inappropriate or offensive names
    - Abusing, threatening, or encouraging for someone to hurt themselves or others
    - Sending inappropriate (e.g. violent, sexually explicit) pictures or communications in-game

    PLAY FAIRLY - PLAY THE GAME AS INTENDED

    Scopely games are created for each player to personalize their experience through their own playstyle and how they choose to engage with the features they like.

    Game rules exist to ensure fair play! Abusing exploits or unapproved tools impact a player's experience while playing the game as intended.

    Ways to play fairly:

    - Support healthy competition where appropriate, focusing on strategy and teamwork
    - Show good sportsmanship, whether winning or losing
    - Follow the rules of the game

    Examples of inappropriate behavior:

    - Disrupting the gameplay experience of others through abuse
    - Lashing out at others who play the game with a different style
    - Cheating or exploiting loopholes in the game, or using mechanics against their intent

    PLAY WITH INTEGRITY - PROTECT YOUR AND OTHER PLAYERS’ IDENTITIES, AND SHARE ONLY WHAT YOU ARE MEANT TO

    Many of our games support social activities that can drive players to share meaningful experiences.

    However, sharing information that is private or protected, such as your or other players’ personal information or account details, can hurt that experience. Sharing personal information may also be illegal in certain circumstances, and any breaches may be punishable by law.

    Ways to play with integrity:

    - Keep your personal account information and unique player ID private and secure
    - Respect your own and others’ privacy
    - Share content that’s meant to be shared
    - Communicate only with other willing players within the game’s chat function or established platforms

    Examples of not playing with integrity:

    - Sharing others’ personal information, such as contact information
    - Impersonating other people or Scopely employees
    - Sharing or selling your account to others
    - Infringing on others’ intellectual property rights or personal content

    PLAY OPENLY - BE WELCOMING TO NEW PLAYERS

    A vibrant, global games community is one that is open to people of all backgrounds, abilities, nationalities, and interests, and all should feel welcome and included.

    New players are joining all the time, and they look to their fellow players for advice, community, and examples to follow.

    Ways to play openly:

    - Be welcoming
    - Be inclusive of new players from all backgrounds, such as those of a different race/ethnicity, gender, religion, sexuality, nationality, ability, and much more
    - Be helpful when talking to new players learning the game
    - Recognize that everyone comes to the game with different experiences

    Examples of not playing openly:

    - Lashing out at those who are learning
    - Bullying or belittling newer players
    - Driving players away from the game

    PLAY WITH ACCOUNTABILITY - BE RESPONSIBLE FOR YOUR ACTIONS AND THEIR IMPACT ON OTHERS

    We encourage players to uphold these guidelines and communication practices across Scopely games and community channels, in addition to the rules in our Terms of Service and rules from particular games or channels.

    Behaviors against our Terms of Service may also lead to account consequences such as warnings, limiting access to chat functions, or suspending your account temporarily or permanently.

    If you believe a player has violated our Terms of Services, you can reach out to customer support at https://scopely.com/customer-support/ to report it to us.



    Scopely is proud to be home to millions of deeply engaged and passionate players worldwide who bring their diverse perspectives and experiences to our player communities.

    By following our Player Community Guidelines, we can all work together to keep our communities safe, inclusive, and fun for all.

    Thank you for playing!

    Promotion Terms & Conditions

    RULES

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    English

    Scopely Promotion Terms & Conditions No Purchase Necessary to Enter or to Win a Sweepstakes
    Purchase may be required for other promotions that are not sweepstakes
    Tournament play is for entertainment only and part of regular game play

    GENERAL TERMS & CONDITIONS. The following Promotion Terms & Conditions (“Promotion Terms”) apply generally to the touchscreen entertainment promotions (“Promotions”) made available by Scopely, Inc. and its affiliates (collectively “Scopely”) through Scopely’s Services, including Scopely’s mobile game applications (“Apps”). Because Scopely runs a wide variety of Promotions, at times some rules may not be applicable and/or additional rules may apply as described here or in the Promotion Notice (defined below).

    HOW IT WORKS. If you have downloaded a Scopely App, you may receive a notice within or outside the App (“Notice”) that you are eligible to participate in a Promotion. A Promotion could be a contest, a sweepstakes, a tournament, a gift with purchase, or a special offer. Terms and Conditions for a given Promotion are available at scopely.com/rules, or wherever otherwise designated in the Notice for the specific Promotion. If you have been directed here, then these are your terms and conditions. In some cases, Scopely may direct you to a website or other location for different or additional rules pertaining to a specific Promotion. Please read them carefully, because if you take advantage of the Promotion, you will be bound by these terms, and they may differ from other Scopely terms and conditions. If you do not agree to the applicable terms, please do not take advantage of the Promotion.

    CURRENT SCOPELY APPS: Looney Tunes™ World of Mayhem; Star Trek™ Fleet Command; Marvel Strike Force; Scrabble® GO; Dice with Ellen; WWE Champions; Wheel of Fortune®: Free Play; The Walking Dead: Road to Survival™; Yahtzee® With Buddies; Dice With Buddies™; Slots Vacation™; Disco Bees™; and Mini Golf MatchUp™.

    PROMOTION DATES AND TIMES. All Promotion begin and end dates and times will be stated within the Promotion Notice. All entries must be received during the promotion period. If a Notice merely states the end date and time, the Promotion begins when you receive the Notice. In some cases, Promotions may only last for a few hours or minutes. All times will be listed in Pacific (California) Time.

    SPONSOR: Scopely Promotions are sponsored by Scopely, Inc., 3530 Hayden Avenue, Culver City, CA 90232 (“Sponsor”). Additional sponsors, if any, will be specifically announced by Scopely.

    ENTRANT ELIGIBILITY. Promotions are open to English-speaking adults who are the age of majority, and for whom these Promotions are otherwise available, legally or otherwise. These Promotions are void wherever they are prohibited. Employees of Scopely, its advertising and/or promotion agencies, and any other entities participating in the design, promotion, marketing, administration or fulfillment of any Scopely Promotion, as well as each parent corporation, subsidiary and/or affiliated company (collectively, “Promotion Entities”), and their immediate family members (defined to include spouses, mothers, fathers, sisters, brothers, sons, daughters, uncles, aunts, nephews, nieces, grandparents and in-laws, regardless of where they live) and members of their households (whether or not related), are ineligible to participate in any Scopely Promotion.

    GAME ELIGIBILITY. Unless you are otherwise redirected in the Notice, these rules apply to all Promotions administered by Scopely.

    HOW TO ENTER. Enter by following the relevant in-App instructions.

    PROMOTION FORMATS (HOW TO WIN). Scopely offers Promotions in several forms:

    Enter to Win Sweepstakes. An enter-to-win Promotion means just that: enter and you will be eligible to win. Follow the Notice instructions to enter for your chance to win the prize listed in the Notice. Try your luck by simply entering the Promotion according to the Notice. Enter-to-Win Sweepstakes are free to enter and an alternate method of entry is not available.

    Fast Play. Players participating in any Fast Play game during the period of time stated will be automatically entered to win a random bonus roll.

    Defeat a Dice Master. Players challenge Dice Masters and are automatically entered to win bonus rolls if they defeat the Dice Master.

    Purchase to Win (“PTW”) Sweepstakes. Each time you purchase the qualifying products, goods, or services outlined in the Notice (up to the number of times listed in the Notice), you will be automatically entered to win the prize described in the Notice. To enter, follow the Notice instructions to complete your purchase, or to enter without making a purchase, follow the “Alternate Method of Entry” instructions listed below. Examples of PTW Sweepstakes: Sweepstakes Bag purchase to win; Bonus Roll purchase to win; Currency Grab purchase to win; Unlock purchase to win.

    Tournament. A tournament is not a sweepstakes, it is a game played for skill and fun, and fees may be assessed without providing an alternate method of entry. The winner of a tournament will receive a prize. Tournament play is for entertainment purposes only and part of game play.

    Tournament Giveaway. A tournament giveaway is a game played for skill and fun, and fees may be assessed without providing an alternate method of entry. The winner of a tournament will receive a prize. Tournament play is for entertainment purposes only and part of game play. From time to time Sponsor will randomly give a small prize of negligible value to winners of tournament play.

    Gift with Purchase. Make a purchase of a qualifying item listed in the Notice and receive a special promotion gift.

    Special Purchase Offer. Take advantage of a special purchase offer and receive a gift or prize as described in the offer and/or Notice.

    Scratchers. Purchase scratchers by following the instructions in the Notice. You may also earn scratchers for free through game play.

    Tournament Sweepstakes. Enter for limited time offers for free tournament entries plus a chance to win Bonus Rolls.

    ALTERNATE METHOD OF ENTRY. The Alternate Method of Entry applies to sweepstakes only and is not available for other Promotions. If you are entering a sweepstakes in which the entry method requires a monetary payment, and you wish to enter without making a purchase, you may do so by following the instructions below. You are allowed the maximum number of entries that any entrant who made a payment is allowed, but you must enter each time and your entries must not be automated.

    The Walking Dead: Road to Survival™. The Alternative Method of Entry must be completed by completing this survey.

    Dice With Buddies™. The Alternative Method of Entry must be completed by sending an email to [email protected] with your date of birth, name and date of the Promotion, and the username and email address that you use in connection with the App.

    Yahtzee® with Buddies. The Alternative Method of Entry must be completed by sending an email to [email protected] with your date of birth, name and date of the Promotion, and the username and email address that you use in connection with the App.

    SELECTION OF WINNERS (FOR TOURNAMENT AND SWEEPSTAKES ONLY).

    Tournament. If you have participated in a tournament, you will be notified of your standing and the winner at the close of the tournament, in-App.

    Sweepstakes. If you have entered a sweepstakes, the drawing will take place within 72 hours after the Promotion ends. Winners will be notified publicly in the App, via public forums, or using an inbox message, as outlined in the Notice.

    PRIZES. The prize(s) will be listed in the Notice (“Prize Package”). All Prize Packages are digital in nature and have only entertainment value. Prize Packages are not transferable, have no cash value whatsoever, and are for entertainment purposes within the particular App.

    ODDS. For any sweepstakes, the odds of winning depend upon the number of entries received.

    PRIZE CONDITIONS: ALL WINNERS ARE POTENTIAL WINNERS UNTIL SPONSOR DETERMINES ELIGIBILITY STATUS. If the potential winner is found to be ineligible, or if an entrant does not comply with the Promotion Terms, then the winner will be disqualified. The Winner waives the right to assert, as a cost of winning a prize, any and all costs of verification and redemption to redeem said prize and any liability that might arise from redeeming or seeking to redeem said prize. Except where prohibited by law, the winner’s entry and acceptance of the prize constitutes permission for Sponsor and/or any Promotion Entities to use said winner’s name, and in some cases, his or her photograph, likeness, statements, biographical information, voice, city, and state address for promotional or advertising purposes, and otherwise in accordance with Scopely’s Privacy Policy (https://www.scopely.com/privacy). All entries are subject to verification prior to awarding of prizes.

    PROMOTION CONDITIONS: VOID WHERE PROHIBITED. Promotions are subject to all applicable federal, state and local laws. By participating, entrants agree to be fully and unconditionally bound by these Promotion Terms and the decisions of the Sponsor, and waive any right to claim ambiguity in any Promotion or these Promotion Terms. Winner and entrants also agree to release, discharge, indemnify and hold harmless the Sponsor(s) and each of their respective officers, directors, employees, representatives and agents from and against any claims, damages, disability, attorneys’ fees, and costs of litigation and settlement, as well as any liability due to any injuries, damages or losses to any person (including death) or property of any kind resulting in whole or in part, directly or indirectly, from (i) redemption, acceptance, possession, ownership, misuse or use of any Prize Package or participation in the Promotion or any Promotion-related activity, or (ii) printing, distribution or production errors. Sponsor may rescind any Promotion found to contain such errors without liability at its sole discretion. Sponsor makes no warranty, representation or guarantee, express or implied, in fact or in law, relative to the use of any prize, including, without limitation, quality, merchantability or fitness for a particular purpose (unless Sponsor provides the prize winner with written warranties). Further, no responsibilities are accepted for any additional expenses, omissions, delays or acts of any government authority.

    RESTRICTIONS. The Prize Package consists of only those items specifically described as part of the prize in the Notice. Sponsor may at its sole and absolute discretion provide different prizes of equal or greater value. Sponsor shall not be liable to any winner or any person claiming through such winner for any claim of failure to supply the prize or any part thereof, by reason of any acts of God, any action(s), regulation(s), order(s) or request(s) by any governmental or quasi-governmental entity (whether or not the action(s), regulations(s), order(s) or request(s) prove(s) to be invalid), equipment failure, threatened or actual terrorist acts, air raid, blackout, act of public enemy, earthquake, war (declared or undeclared), fire, flood, epidemic, explosion, unusually severe weather, hurricane, embargo, labor dispute or strike (whether legal or illegal), labor or material shortage, transportation interruption of any kind, work slow-down, civil disturbance, insurrection, riot, or any other cause beyond Sponsor’s sole control.

    LIMITATIONS OF LIABILITY. Sponsor is not responsible for: (1) lost, late, misdirected, undeliverable or incomplete entries due to system errors or failures, faulty transmissions, or other telecommunications malfunctions and/or entries; (2) technical failures of any kind; (3) failures of any of the equipment or programming associated with or utilized in the Promotion; (4) unauthorized human and/or mechanical intervention in any part of the entry process or the Promotion; (5) technical or human error which may occur in the administration of the Promotion or the processing of entries; or (6) any injury or damage to persons or property which may be caused, directly or indirectly, in whole or in part, from entrant’s participation in the Promotion or receipt or use of any prize. If for any reason an entrant’s entry is confirmed to have been erroneously deleted, lost or otherwise destroyed or corrupted, entrant’s sole remedy is another entry in the Promotion. Sponsor may prohibit an entrant from participating in the Promotion or winning a prize if, in its sole discretion, it determines that said entrant is attempting to undermine the legitimate operation of the Promotion by cheating, hacking, deception, or other unfair playing practices (including the use of automated quick entry programs) or intending to annoy, abuse, threaten or harass any other entrants or Sponsor’s representatives. If for any reason this Promotion is not capable of running as planned, including, but not limited to, infection by computer virus, bugs, tampering, unauthorized intervention, fraud, or any other causes beyond the reasonable control of Sponsor which corrupt or affect the administration, security, fairness, integrity or proper conduct of the Promotion, then Sponsor reserves the right at its sole discretion to cancel, terminate, modify or suspend all or any part of the Promotion and to select a potential winner from among all eligible entries received by Sponsor up until the time of such cancellation, termination, modification or suspension, as applicable. Caution: any attempt by an entrant to deliberately damage the website or undermine the legitimate operation of the Promotion may be in violation of criminal and civil laws and should such an attempt be made, Sponsor reserves the right to seek civil and/or criminal prosecution and damages (including attorneys’ fees) from any such entrant to the fullest extent of the law.

    JURY TRIAL WAIVER. Except to the extent prohibited by law, as a condition of participating in this Promotion, entrant hereby waives any right he/she may have to a trial by jury in respect of any litigation related to or directly or indirectly arising out of or relating to such Promotion, or any document or agreement entered into in connection herewith (including these Promotion Terms), or any of the transactions contemplated hereby or thereby.

    PRIVACY POLICY AND TERMS OF USE. By entering a Promotion, each entrant acknowledges that they have read and agree to Scopely’s Terms of Service (located at https://www.scopely.com/tos), and that any of the entrant’s information made available to Scopely in connection with a Promotion will be treated in accordance with Scopely’s Privacy Policy (located at https://www.scopely.com/privacy/). The rules for any given Promotion shall supersede any contradictory terms contained in the Terms of Service. Each entrant acknowledges that if he/she is a winner, certain of his/her identifying information may be publicly disclosed to announce the winner and/or disclosed to third parties at least as required by law, including, without limitation, on a winners list.

    WINNER(S) LIST. A winners list becomes available after completion of a Promotion and will remain up for 120 days. You may write to Sponsor at the address below to request a copy of the list. To do so, please include a self-addressed, stamped envelope (WA residents excluded), and request the name of the winner for a particular Promotion (note: you will generally receive the username for privacy purposes). You must include the name and date of the Promotion, including the game title.

    UK Tax Strategy

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    English

    The following document is published in accordance with the requirements under Part 2 of Schedule 19 of the Finance Act 2016 for the financial year ended December 31, 2022.

    Introduction

    This document outlines the approach to tax strategy, tax risk, and planning for the UK
    subsidiaries and affiliates within the Group, and is meant to cover all applicable taxes for the UK sub-group, including corporate tax, payroll taxes, and VAT. This strategy is reviewed and approved by UK senior leadership.

    Risk Management and Governance

    As outlined in our Code of Conduct, the Group and its employees are committed to not only complying with all applicable laws and regulations, but also going above and beyond these standards to conduct our business in the most honest and ethical manner possible wherever operations are maintained.

    This level of standard in the Code of Conduct is applied to our approach in managing tax risk and governance in the UK, and in all jurisdictions where the Group operates. We diligently monitor applicable tax laws and regulations to ensure that UK tax is paid appropriately and timely, tax reporting and disclosure requirements are met, and that tax risk is minimized.

    Due to the complexity and constant changes in global tax, we manage tax risks and uncertainty internally, but we also seek guidance from outside advisors to inform our decision making and strategy. Key tax decisions are made at the appropriate levels and in consultation with senior leadership.

    Tax Planning

    Our focus is to ensure compliance with applicable laws in keeping with our Code of Conduct, and that tax planning aligns with the natural state of business expansion and operating objectives. We seek guidance from external advisors as appropriate to navigate complex tax rules and minimize uncertainty in interpretation.

    Level of Tax Risk

    The UK sub-group is part of a much larger global tax group, and therefore the level of tax risk is assessed as a global organization. The Group is focused on proactively assessing the relevancy and applicability of tax legislation to maintain low levels of tax risk or uncertainty of tax positions. External tax advisors are consulted as needed.

    Engaging with HMRC

    The UK sub-group aims to have a professional, transparent, and collaborative relationship with the HMRC on all tax matters whether historic, future, or prospective.

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