Privacy Policy
Effective Date: 2024.09.21.
Introduction
What Information Do We Collect
How We Use Your Information
How We Share Your Information
Cookies and Related Technologies
International Data Transfers
Retaining and Deleting Personal Information
Our Policy Concerning Children
Links and Third-Party Services
Security of Your Information
Your Privacy Rights
Amendments
Contact Us
Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC
Click HERE or Scroll down for the California Notice for California Residents
Introduction
Flyway Games, Inc. (“we”, “our”, “Company” or “us”) collect, use and process information about you (“you”, “user”, or “player”). We provide various services related to the “Ascend to ZERO” Game (i.e. game, website, event, survey, or customer service) ("Games and Services"). This Privacy Policy (“Policy”) covers the personal information that is provided, collected, or generated when you access, use or subscribe to our Games and Services, except where separate privacy policies or terms and conditions apply. This Policy applies to our Games and Services and also explains the rights and choices you have with respect to this data, and how you can communicate with us. This Policy does not apply to and cannot control activities when you click or visit other sites from our Game and Services.
We will occasionally update this Policy. When we do, we will revise the effective date above. While we will periodically inform you of this Policy or any material changes to it, your continued use of our Games and Services after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information. From time to time, we may ask you to confirm your acceptance of this Policy when we offer our Games and Services.
What Information Do We Collect
We will collect the following categories of information that may directly or indirectly identify or describe you or your device or information that may be reasonably capable of being associated with or reasonably linked to you or your device. The information you provide to us may differ depending on the circumstances. For example, these include:
International Data Transfers
We operate globally and to provide our Games and Services may transfer your data to countries and other regions outside of the country where you are located. If your personal information is transferred, stored or processed by us, we take reasonable steps to safeguard the privacy of your personal information, including entering into confidentiality and standard contractual clauses with vendors where appropriate. Additional information concerning the international transfer of your information is available depending on your region. See the supplemental terms section below for more information.
Retaining and Deleting Personal Information
In principle, we will remove your personal information without delay after the purpose of collecting personal information is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that the information cannot be reproduced. However, we may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or any other agreement we may have with a player.
Our Policy Concerning Children
We do not knowingly collect, use or share any information about children without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with information, you can contact us and request your child’s information to be deleted from our system.
Links and Third-Party Services
If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave our website and go to the website you selected. Because we cannot control the activities of third parties, we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Games and Services, you should consult that site’s privacy policy before providing any personal information.
Security of Your Information
We have put in place appropriate security measures, including encryption and de-identification, to protect your personal information. In addition, we limit access to your personal information to those employees, agents, persons, or companies who have a business need to know or access the information. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality where appropriate. Please note, however, that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use therefore cannot be guaranteed.
Your Privacy Rights
Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any other question, please contact us by sending an email to the address specified in the “13. Contact Us” section. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Amendments
We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Games and Services. If we make material changes, we will post a prominent notice on our websites or in our Games and Services or give you other reasonable notice before any material changes take effect. All other changes are effective upon posting.
Contact Us
If you have any questions about this Policy, or your dealings with our Games and Services, please contact us by sending an email to cb_contact@flywaygames.com.
This Privacy Policy has been translated into other languages for your convenience. In case of any discrepancies between the English version and the other versions, the English version shall prevail. However, Korean Privacy Policy shall prevail for users based in Korea.
Appendix. SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC
This portion of our Policy applies to residents of the jurisdictions indicated below. In the event of a conflict between the Policy and this section, this section supersedes and controls.
Privacy Rights for United States Users
Several U.S. states provide their residents with rights to:
a. Confirm whether we process their personal information;
b. Access and delete certain personal information;
c. Take their data from one location to another (data portability);
d. Opt-out of personal data processing for targeted advertising and sales;
e. Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose;
f. Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights submit a request form send us an email to cb_contact@flywaygames.com. To appeal a decision regarding a consumer rights request, follow the instructions in the written notice we will provide to you.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: (e-mail: cb_contact@flywaygames.com). However, please know we do not currently sell data triggering that statute’s opt-out requirements.
California
If you are a California resident, you may have additional rights as detailed below. Within the preceding 12 months, we have collected or disclosed the following categories of personal information about you:
a. Identifiers, such as SteamID64, nickname, email address, postal address, phone number, etc.
b. Characteristics of protected classifications such as sex, date of birth, language, nationality, etc.
c. Internet or other similar network activity, such as browsing behavior while using our Games and Services (e.g., device model, OS version, MAC address, device ID, advertisement ID (ADID, IDFA), game information, etc.), identifiers such as IP address.
d. Geolocation information obtained by IP address.
We determine the retention period for each of the categories of personal information listed above based on our business or commercial purposes for obtaining the information, our legal or regulatory requirements applicable to such information, and in relation to litigation or to protect our rights.
a. Right to Know & Right to Access
You have the right to request the following information from us up to two times within a 12-month period:
b. Right to Delete
You have the right to request that the personal information collected from you be deleted.
c. Right to Correct
You have the right to correct your personal information. You can edit your personal information via the in-game “Setting” menu or email to cb_contact@flywaygames.com.
d. Right to Non-Discrimination
You have the right not to be discriminated against for exercising these privacy rights.
e. Right to opt-out of Selling and Sharing
You have the right to opt-out of the selling and sharing of your personal information as defined by California law by requesting that your personal information not be sold or shared in any form. With respect to targeted advertising, you can control the sharing of your personal information for targeted advertising purposes through our website by opting out from advertising cookies through the cookie banner.
HOWEVER, WE HAVE NOT “SOLD” PERSONAL INFORMATION TO THIRD PARTIES AS THAT TERMS IS DEFINED BY THE CCPA WITHIN THE PAST 12 MONTHS. ALSO, WE HAVE NOT “SHARED” PERSONAL INFORMATION WITH THIRD PARTIES FOR THE PURPOSE OF CROSS-CONTEXT BEHAVIORAL ADVERTISING.
f. Rights for California Minors
Minors under the age of 16 have the right to request the deletion, correction or copies of information publicly posted by you, such as on forums or bulletin boards.
g. Shine the Light
You have the right to request the categories of the personal information that we disclosed to third parties for their direct marketing purposes during the past 12 months and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for their direct marketing purposes.
h. Limit Use and/or Disclosure of Sensitive Personal Information
You have the right to limit our use of your sensitive personal information. However, WE DO NOT USE YOUR SENSITIVE PERSONAL INFORMATION for purposes that require us to offer this limitation option. If we collect your sensitive personal information, we will get your consent.