Data privacy

Effective date: July 17, 2020

Treasure Hunters SA is a Swiss company based in Delémont. The company publishes and operates a mobile application called Treasure Hunters.
To do this, we need information about you. The protection of your privacy is very important to us. We only use your information to the extent that we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you play our game, use our websites, purchase merchandise or participate in live events and promotions the "Services".
You should also read our Terms of Use which set out the contract between you and Treasure Hunters.

1. Who decides how your Personal Information is used?
Treasure Hunters SA, Route de Rossemaison 100, 2800 Delémont, Switzerland "Treasure Hunters" is the data controller responsible for making decisions about how we use your personal information.
If you have any questions or comments about this policy, you can email us at [email protected]

2. The information we collect about you and how we use it
This Privacy Policy covers our use of any information that can or may be used to identify you "Personal Information". It does not cover information that cannot be used to identify you "Anonymous Data".
We need to collect and use certain Personal Information to provide you with the Services and to fulfill the promises we make to you in our Terms of Use:
When you register for our Services, you voluntarily provide us with Personal Information by providing it to us, such as when you create an account. We collect and use this information to authenticate you when you create an account and use the Services, to ensure that you are eligible and able to receive the Services, and that you receive the correct version of the Services. This information includes the in-game username you choose to use on our Services, and the internal account identifiers we assign to your account.
You must have an account with a compatible external single sign-on service provider to use our Services. As such, the Personal Information we collect also depends on the external provider you choose to use, its Privacy Policy, and what your privacy settings for those services allow us to see when you use those services to access the Treasure Hunters Services.
If you choose to link your Google Account to the Services, we will collect your Google email address and an authentication token provided by Google.
If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if you authorize it, your email address registered with Facebook.
If you choose to link your Apple account to the Services, we will collect your email address on file with your Apple ID account or an associated private email address if you use the Hide My Email Address option provided by Apple.
Depending on the specific Service you register for, we may support additional single sign-on services from external providers and collect additional Personal Data from them.
Some external providers may inform you that they make additional information, such as your public profile, available to us when you use their single-session services. We do not collect this information from them.
We collect and use information about your device's location when you use our Services (and, if you choose to enable background location tracking for our Services, when you are not directly interacting with the Services), including how you move and what events occur during game play. Our Services include location-based gameplay, the main feature of which is to provide a game experience that is tied to your actual location. We therefore need to know where you are in order to make the game work for you, and to plan the location of game resources (e.g., for checkpoints or the location of a treasure). We identify your location using a variety of technologies, including GPS, WiFi points through which you access the Service, and triangulation via mobile/cellular towers.
We also collect and use your actions and achievements in the game, as well as certain information about your mobile device (including device identifiers, operating system, model used and configuration, settings and information about third party applications or software installed on your device) to operate the Services for you and customize your game and user experience.
We also use the above information to display in-game sponsored locations that are in close proximity to you as part of the game experience.
We also use the above information to provide you with technical and customer support.
You also provide us with Personal Information when you make a purchase through us, subscribe to our publications, register for a live event, enter a contest, promotion, sweepstakes or survey, or communicate with us. Depending on the Services you use, this may include your name, mailing address, telephone number, country of residence, date of birth (if required to verify eligibility), and email address. We use this information to provide you with the Services and to provide you with appropriate customer support.
In addition, we have a legitimate interest in - and rely on - using your Personal Data as follows:
• Use your IP address, the type of browser and operating system you use, the web page you visited before accessing our Services, the pages of our Services you visited or features you used, the time you spent on those pages or features, the links to our Services that you click on, advertising and device identifiers, and the actions you take while playing games, your in-game user preferences and settings, and your purchases on our app to understand who is using our Services and how.
• Use your contact information, including your email address, to communicate with you to provide technical and customer support.
• Use your internal account ID to attribute to your account any user content (such as local points of interest) that you choose to submit to Treasure Hunters through the Services.
• Use your email address and device information to share updates and news with you, either in-game or via email. You can unsubscribe at any time in your device settings or in the application settings.
• Analyze your game actions and performance to show you rewards, promotions or other offers regarding our services that are tailored to your personal user experience. You may choose to object to this and certain other processing of your personal data by following the steps described in Section 7 below.
• To provide social features in our games so that you can interact and play with other players, including storing your communications with those players, so that you can find your friends and be found by them, and so that you can share your game experience and achievements with your friends.
• To provide augmented reality experiences. To do this, Treasure Hunters needs to locally retrieve geospatial augmented reality data from your device's camera. This geospatial data is then integrated by Treasure Hunters servers to allow you and other players to view and interact with the same virtual objects at the same time in a shared physical space. Please visit our Help Center for more information about augmented reality experiences and privacy.
• To provide new or additional features for our Services.
• To organize and run live events based on or featuring our games. Note that when you participate in live events, your in-game actions and achievements, your in-game username and avatar, your team and other elements of your in-game profile will be visible to other participants and the public (e.g. on leaderboards posted at the event and online).
• Use your in-game actions and achievements, as well as certain information about your mobile device (including device IDs, operating system, model, configuration, settings, and information about third-party applications or software installed on your device), to implement anti-cheating and anti-cheating measures against behavior prohibited by our Terms of Service, in order to ensure a fair game experience for all players.

• To carry out legal or regulatory communications and to establish, exercise or defend legal claims and/or legal proceedings.
We will only use your Personal Information in the following ways and for the following purposes if you authorize us to do so:
Send you marketing materials via email or through in-app notifications. You can unsubscribe at any time in your device settings or in the app settings.
We also rely on your consent when we use cookies or similar technologies. Please see our Cookie Policy for more information on how we use them. To the extent that cookies collect Personal Data, we will process it only with your explicit consent, in anonymous or pseudonymous form.
Although you can disable the use of cookies through your browser settings, Treasure Hunters does not currently respond to a "Do Not Track" signal in the HTTP header of your browser or mobile application due to the lack of an industry standard on how to interpret this signal.

3. Those with whom we share information
We will not share the Personal Information we have collected about you, except as described below:
• Information shared with our service providers. We hire outside service providers to work with us to administer and provide the Services. In doing so, they will process your Personal Information on our behalf. These external service providers have access to your Personal Information solely for the purpose of providing services on our behalf in accordance with this Privacy Policy, and we ensure that each of them is contractually bound not to disclose or use your Personal Information for any other purpose.
The service providers we use help us to:
• perform, operate and maintain our Services through a third party platform and software tools;
• perform content moderation and failure analysis;
• launch email and mobile messaging campaigns;
• perform game and marketing analysis;
• Manage live events, competitions, sweepstakes and promotions, including player registration, registration and entry management, eligibility verification and prize distribution;
• provide payment allocation;
• Provide technical and customer support;
• and process payments for live event ticketing or other purchases.
Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third Party Service in accordance with their own Privacy Policy. These external service providers do not share your financial information, such as your credit card number, with Treasure Hunters, but they may share with us limited information related to your purchase, such as your zip or postal code.
Information Shared with Other Players. When you use the Services, and in particular when you play our game, use social-type features in that game, (including multi-game features), or participate in live events, we will share certain Personal Data with other players. This Personal Data includes your game profile (such as your username, avatar, online status and team), your in-game actions and achievements, the actual location of game resources you interacted with while playing the game, and your in-game public messages. In addition, some games are linked to third-party sharing features on your device that you may use to disclose Personal Data to third parties outside of the Services; Treasure Hunters does not control and is not responsible for the practices of these third-party sharing features.
Publicly Shared Information: When you use the Services, and in particular when you play our games, use advanced features or participate in our forums, the following information about you may be shared on publicly accessible web pages and thus become publicly available: your username, in-game profile, performance and public posts.
Information Shared with Third Parties. We share anonymous data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with other third parties for their direct marketing purposes.
Information disclosed for our protection and the protection of others. We cooperate with government and law enforcement authorities or private entities to enforce and comply with the law. We only share your personal information with government authorities, law enforcement or private entities when we reasonably believe it is necessary or appropriate:
• to respond to complaints and legal proceedings (including subpoenas and warrants);
• to protect our property, rights and safety or that of a third party or the general public; and
• to investigate and stop any activity that we consider illegal, unethical or actionable.
Information disclosed in connection with commercial transactions. The information we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party in a transaction such as a merger, acquisition or sale of assets, or if our assets are acquired by a third party in the event that we cease operations or go out of business, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer as part of that transaction.

4. How your Personal Information is transferred
Treasure Hunters operates its Services worldwide. Your Personal Information will most likely be transferred to and stored in a country outside of your home country, including the United States, for the purposes described in this Privacy Policy. Data protection laws in these countries may not be the same as in your home country.
If we transfer your Personal Data from the EEA to other countries, including the United States, we ensure that your Personal Data receives a similar level of protection as in the EEA by ensuring that at least one of the following safeguards is applied:
The country to which your Personal Data is transferred is a country that the European Commission has deemed to provide an adequate level of protection for Personal Data, such as the EEA.
We use specific contracts approved by the European Commission that give Personal Data the same protection as in Europe when we work with service providers.
When we work with service providers in the United States, they are part of the EU-US Privacy Shield, which requires them to provide the same level of protection for your Personal Data as in the EEA.

5. How we protect your Personal Information
We have appropriate security measures in place to prevent accidental loss, unauthorized use or access, alteration or improper disclosure of your Personal Information. We also restrict access to your Personal Information to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and are subject to a duty of confidentiality. We have procedures in place to deal with any suspected breach of privacy and will notify you and any applicable regulator of any such breach where we are legally required to do so.

6. How long we will keep your Personal Information
We retain your Personal Information for as long as necessary to provide the Services to you and to fulfill the purposes set forth in this Privacy Policy. This is also the case for any person with whom we share your information and who performs services on our behalf.
When we no longer need to use your Personal Data and we no longer need to retain it to comply with our legal or regulatory obligations, we will delete it from our systems or make it anonymous so that it can no longer be associated with you. Upon deletion of Personal Data, we will take commercially reasonable and technically feasible steps to make such Personal Data unrecoverable or unprintable.
We keep data for 12 months on anyone who has had their account terminated, for example for cheating.

7. Your rights and choices
You have certain rights with respect to your Personal Information. To exercise these rights, please contact us at [email protected]
You can:
• Request access to the Personal Information we hold about you.
• Delete or correct your Personal Information. The easiest way to update your account information is to use your application settings.
• Ask us to stop processing your Personal Data, including for direct marketing and promotional purposes. Please be aware, however, that there are times when we may need to use your Personal Information to provide you with Services.
• To have your Personal Data transferred to another organization (where technically possible).
• Complain to a regulator. We would appreciate you raising your concerns directly with us and would prefer that you contact us first. However, if you are based in the EEA and you believe that we have not complied with data protection laws, you can file a complaint with your local regulator.
The law provides exceptions to these rights in certain circumstances. If you cannot exercise any of these rights because of such an exception, we will explain why.
We offer you choices regarding the collection, use and sharing of your Personal Information and we will respect the choices you make. Please note that if you choose not to provide us with the Personal Information we request, you may not be able to access all the features of the Services.
Our goal is to provide the information or complete the result you request within 30 days.

8. Children
Unless otherwise specified for a particular Service, children are not permitted to use the Services, and we do not collect Personal Data about them. We define "Children" as follows:
• EEA Residents: any person under the age of 16 or the age required to consent to the processing of Personal Data in your country of residence.
• Residents of the Republic of Korea, any person under the age of 14.
• Residents of other regions: anyone under the age of 13.
• Treasure Hunters Game Resources contains information about the age requirements for each of our applications.
For Services that allow participation by Children, parents or legal guardians ("Parents") must provide verified consent. Where parental consent is required, Treasure Hunters recommends that Parents monitor the Child's online activities and use of the Service.
Verifiable parental consent is required for the collection, use or disclosure of a child's Personal Information. Treasure Hunters will not collect, use or disclose any Personal Data of a child if the child's parent or guardian does not provide such consent. We may ask a Child to provide a Parent's email address in order to request such consent, and the Parent's email address will be deleted if consent is not provided within a reasonable time.
Once verified, a parent may consent to their child accessing the Service.
Parents have the right to review their Child's Personal Data, to have their Child's Personal Data deleted, and to refuse the collection, use and/or disclosure of their Child's Personal Data by notifying us. As a parent, you understand that Treasure Hunters has a legitimate interest in providing your Child's Personal Data collected through the Services to outside vendors for the sole purpose of administering or providing the Services, as described in paragraph 3 of this Privacy Policy.
If we learn that we have collected Personal Information from a Child and we do not have parental consent, we will take steps to delete that information from our files as soon as possible.

9. Changes to this Privacy Policy
Any Personal Information we collect is handled in accordance with the Privacy Policy in effect at the time the information is collected. We may make changes to this Privacy Policy from time to time. You will receive reasonable notice of any material changes.

10. Third parties
When using our Services, you may access links to websites and services owned or operated by third parties (each a "Third Party Service"). Any information you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner or operator's Privacy Policy. We are not responsible for the content, privacy or security practices and policies of any Third Party Service. To protect your personal information, we recommend that you carefully read the privacy policies of any Third Party Services you access.

11. Communications specific to California residents
California law requires us to disclose certain information about your data. We do not sell your Personal Information. The information listed in Section 2 falls into the following categories of the California Consumer Privacy Act (CCPA): identifiers, business information, information about activity on the Internet or other electronic networks, geolocation data, and visual information.

Cookies
Our game and websites ("Services") use cookies, which are small text files that are placed on your computer or device by a web server when you access our Services. We may place and access cookies and other similar technologies on your computer or device, which are known as "internal cookies. Cookies may also be placed and accessed by third parties, known as "third party cookies" as described below.
We use cookies and local storage to track aggregate usage and web traffic on our Services, customize and improve our Services, help you navigate our Services, provide you with content specific to your interests, and send you advertisements.
We also use "web beacons" which are small pictograms with a unique identifier that may be included in our Services, for example, to send or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user's hard drive or terminal, web beacons are typically embedded invisibly in web pages (or in an e-mail).

1. Types of Cookies
We use the following types of cookies:
• Strictly Necessary Cookies: These are cookies that are essential for you to use the Services, for example, to browse our websites and use their features (for example, cookies that allow you to log in to the Services).
• Performance Cookies: These are cookies that collect information about how you and other visitors interact with our Services (e.g., which pages are viewed the most) and when. The information collected by these cookies is used to improve the operation of our Services.
• Functional Cookies: These are cookies that allow our Services to remember choices you have made (such as your login information) and to provide you with content and features specific to you. For example, providing you with relevant content using a cookie that identifies your location.
• Advertising Cookies: These are cookies that are used to display ads that are more relevant to you and your interests. We may also share this type of information with third parties for these same purposes.
The types of cookies described above may be "session cookies" or "persistent cookies". Session cookies are only stored on your device while you are using the Services and are deleted when you log out of the Services or close your browser. Persistent cookies remain on your device for a period of time after you log out of the Services or close your browser.

2. Third Party Cookies
Some cookies may be placed by third parties when you use the Services, as some of the third party service providers we engage (including third party advertisers) may place their own cookies on your hard drive or terminal. These cookies may provide information to these third parties about your browsing habits or may be used for security purposes. Some also help to deliver ads that are more relevant to you.
For example, our websites use Google Analytics, a web analysis service provided by Google, Inc. ("Google"). Google Analytics uses non-operational cookies, which are text files placed on your computer, to help the website analyze how visitors use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. At our request, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
We also use the Facebook pixel service. The Facebook pixel is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions you take on other websites. We use it to ensure that our advertising on Facebook is shown to the right people and is effective. When you visit our websites and take an action, it triggers the pixel to report that action to Facebook.
By using our websites, you consent to the processing of data about you by Google and Facebook in the manner and for the purposes set out above.

3. Cookies Placed by Third Parties When You Visit Third Party Websites or Services
We also maintain a presence for Treasure Hunters and its Services on third party websites and services that are not hosted by Treasure Hunters. If you visit or use third party websites or services, these third parties may place cookies or similar technologies on your computer or device. For more information about the cookies or similar technologies that these third parties use, please see the cookie policies of the third party services.

4. Cookie settings
Although most browsers automatically accept cookies, you can change your browser options to stop accepting cookies automatically or to warn you before accepting cookies. However, if you do not accept cookies, you may not be able to access all portions or features of the Services.
If you continue to use the Services, you consent to our use of cookies as described in this Cookie Policy.