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Privacy Policy

This Pullz privacy policy (the "Privacy Policy" or "Policy") is provided to help users accessing and/or using the Services understand our practices regarding how we collect, use, share, and protect personal information. In this Privacy Policy, "Pullz" refers to Delta Two Inc. and its subsidiaries. We may also refer to Pullz as "we" or "us."

This Privacy Policy is incorporated into the Pullz Terms of Use (which can be found at https://www.pullz.com/terms-conditions ("T&C’s") and is an integral part thereof, such that the Limitation of Liability, Indemnification, and Miscellaneous sections thereof shall also apply to this Privacy Policy. Terms not defined here shall have the meaning ascribed to them in the ToU.

This Privacy Policy applies whenever you play the Games that link to this Policy, or otherwise access and/or use products, Games, features, content, and other services provided by Pullz on web, PC/mobile applications, or any other applicable platforms and/or devices ("Services").

Any personal information you may provide through your use and/or access of the Services is subject to the terms of this Privacy Policy, as may be updated by Pullz from time to time. Please read this Privacy Policy carefully before accessing and/or using the Website and/or the Services. This Privacy Policy does not apply to any Third Party Content, even if such content is available or accessible through the Website and/or our Services. "Personal Information" means any information relating to an identified or identifiable natural person.

You are advised that you are under no legal obligation to provide us with your Personal Information; however, not providing us with certain Personal Information may prevent us from delivering all or some of our Services to you.

If you provide us with information about third parties (whether an individual or a corporate entity), you confirm that (a) you have obtained that third party's consent to provide us with such information for use as described herein in accordance with applicable law; and (b) you have full authority to act on behalf of such person or entity. For the avoidance of doubt, the term "you" as used herein refers to both yourself and any third party on whose behalf you are acting.

BY USING THE SERVICES, YOU AGREE TO THE COLLECTION, DISCLOSURE, STORAGE, AND USE OF PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT WISH FOR PULLZ TO COLLECT, STORE, USE, OR SHARE THE PERSONAL INFORMATION YOU PROVIDE IN THE WAYS DESCRIBED IN THIS PRIVACY POLICY, YOU SHOULD NOT PLAY PULLZ'S GAMES OR USE OUR SERVICES (INCLUDING THE WEBSITE).

All consents provided herein with respect to Personal Information shall also apply to other types of data and affairs (such as "person's private affairs" as defined in the Protection of Privacy Law, 5741 – 1981 ("IPPL")), without derogating from our right to use such data and affairs (unless restricted under applicable law). You shall not have a right to consideration or any other right arising from the creation or exploitation of analytic data or other information collected hereunder.

The Services are not directed toward young children or minors under the age of 18. Please do not use the Services if you are under the age of 18. Pullz is committed to complying with applicable laws and regulations regarding minors, including the United States' Children's Online Privacy Protection Act. Specifically, Pullz will not knowingly collect or maintain any personally identifiable information from individuals under the age of 18. If you are a parent or guardian who has discovered that your child has submitted personally identifiable information, Pullz will make reasonable efforts to delete the information from its database upon your request. To request the deletion of your child's information, please send an email to support@pullz.com.

When used herein, the term "including" shall mean "including among others."

 

Collection of Personal Information

Pullz collects Personal Information to fulfill one or more of its functions and activities, as described in this Privacy Policy.

1.1 Personal Information That You Share With Us

When you use our Services, you may voluntarily provide us with information (for example, when setting up your account or contacting customer support), such as your age or date of birth, first and last name, email address, password, contact information (such as your phone number), social security number (which, for the avoidance of doubt, will not be stored or saved in any form), and other information we request in connection with your account and/or to help support the secure use of your account and the Services. You may also provide information necessary for us to deliver requested support, and/or information to help us improve our Services (such as feedback).

When using our Services, you may choose to create a player profile that other Pullz users can view. In your profile, you may include information such as a profile photo, username, gender, biographical details (such as age or age range), approximate location, links to your social media profiles, and details about the tournaments, competitions, and games you participate in.

You may also provide us with Personal Information in other ways, including through responses to surveys or research we conduct, participation in contests and sweepstakes, via social media, by participating in group communications or chats, at conferences, conventions, and other events.

1.2 Personal Information We Receive from Others

We may collect or receive Personal Information about you from third parties. For example, third-party applications (such as social networks like Facebook), app stores, or third-party login services may provide us with information about you.

If you access any of our Services through external applications, we may receive certain information about you from the provider of such application. The information we receive depends on the third-party application, your privacy settings, and, where applicable, your friends' privacy settings on that platform.

Information received from external applications may include your name, profile picture or its URL, user ID number (such as a Facebook ID), which may be linked to information about your friends, including their identifiers, names, and profile photos. It may also include the login email you provided to the third-party application, your physical location and that of the devices you use to access our Services, gender, birthday and/or age range, information about your activities on or through third-party applications, other information you have shared on those platforms, and any other information that you or the provider of the third-party application choose to share with us.

If you access our Services through any external application, or connect our Services to one, you should also review that application's Terms of Service, Privacy Policy, and applicable documentation.

If you are unsure what information an external application is sharing with us, please consult that application's documentation to learn more about their privacy practices.

1.3 Automated Collection

We may collect information related to your use of the Services and your activity within them, including records of prizes you have won, bonus funds you have received, and virtual items you have obtained.

Like many websites, we and our service providers and other parties (such as those who provide third-party content) may use automated data collection methods, including cookies. A cookie is a small data file transferred to your device for record-keeping purposes, and the information it contains may be linked to Personal Information. We use cookies to improve our Services, serve you content we believe may be relevant to you, and to further develop or create new services.

Third parties may also place or read automated data collection measures on your browser, device, or within the Service, and those measures are subject to the respective third party's policies. For example, we may use Google Analytics or similar vendors to gather information about user behavior and demographics. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. To opt out of Google's data collection and processing, visit https://tools.google.com/dlpage/gaoptout.

Automated data collection methods may include web beacons, which allow the party using them to determine whether a page was visited or an email was opened; tracking pixels, which help advertisers exclude existing users from certain promotions, identify the source of a new installation, and deliver ads; and local shared objects (flash cookies), which help reduce fraud, retain in-game preferences, and improve load times.

Information collected through automated means may include device type, operating system and version, device identifiers (such as MAC address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI)), browser type and language, referring page, exit page, platform type, number of clicks on a page or feature, domain names, landing pages, pages viewed, time spent on particular pages, game state, and the date and time of activity on our websites or games. In some cases, we may associate this information with your social network ID or Pullz user ID.

1.4 Personal Information Generated in User Content

Our Services may allow you to communicate or share information with Pullz and other users through activities such as participating in player forums and message boards, posting public comments on other users' profiles or game boards, sending private messages or invitations to other users (directly or via email), chatting with other users, and posting photos or drawings.

Please be aware that, as outlined in our Terms, you may choose to share information about yourself through the content you post, including in chat rooms, blogs, message boards, public player profiles, and similar forums. Any information you share in these spaces should be considered public, and you should have no expectation of privacy or confidentiality. We may use any information you make available through user content in accordance with our Terms, including this Privacy Policy.

You should also be aware that any Personal Information you submit - including videos and images - may be accessed, viewed, collected, or otherwise used by other users or third parties. We are not responsible for the Personal Information you choose to make public through any content you share.

To enable certain social features, you may be able to import your address book contacts or enter them manually to locate and invite contacts to join you in our games or other parts of our Services. You are responsible for obtaining your contacts' permission before sharing their contact details with us. We may also receive information about you from other Pullz users who import or enter their contacts.

1.5 Payment Information

When you make purchases through the Services, we may process your payments directly or through third-party payment processors. These third-party services constitute Third Party Content as defined in the T&C’s. In connection with payment processing, certain financial information may be collected, including your name, email address, billing address, and other relevant billing details. If a third-party service handles your payment information, you may need to contact that provider directly to delete your payment or billing details, as we will only retain minimal secure access to those records as necessary to provide the Services.

1.6 Aggregate Information Collected

We reserve the right to collect information that does not identify you individually ("Analytic Data"). This data may be collected when you visit our website or interact with the Services. We may collect, use, store, and transfer Analytic Data without restriction. Such information may include the data described in Section 1.3 (Automated Collection), the date and time of your visit, the phone network associated with your device, device data, the features of our Services you accessed, and other usage data. While we make every effort to respect the privacy preferences of our users, we are currently unable to respond to "Do Not Track" signals from your browser.

We also reserve the right to collect and generate Analytic Data such as averaged or aggregated data, benchmarks, analytics (such as usage habits), comparisons, and recommendations, as well as other calculations derived from or referencing such data. We may combine this data with information from third parties. All rights, title, and interest in Analytic Data are solely owned by us. We have the unrestricted right to use, transfer, sell, or otherwise commercialize Analytic Data for any purpose without notice or obligation to you, provided it does not identify you personally.

Your interactions with our Services may be tracked across platforms and/or devices.

1.7 Cache Data

A cache is a component of your mobile device that stores data transparently for record-keeping purposes. Cache data does not identify users but does identify your device. Most browsers and applications are initially configured to accept such data. If you prefer, you may adjust your device settings to prevent this data from being stored while using the Services. Please note that certain features may only be available when this data is collected. We may use cache data to assist with data collection and to monitor application usage trends in order to improve your experience.

 

2. Personal Information Usage

2.1 Pullz uses Personal Information for the purposes described in our Terms (including this Privacy Policy), to provide the Services and complete requested transactions, to comply with applicable law, and for other legitimate business purposes, including fulfilling our contractual obligations. Such uses may include:

  • Creating your accounts and enabling you to participate in our tournaments, competitions, and games;

  • Operating, improving, and optimizing our Services and user experiences, including measuring interest in and engagement with our Services;

  • Processing payment card and other financial information to facilitate purchases;

  • Identifying and suggesting connections with other users and personalizing your experience;

  • Enabling users to communicate with one another;

  • Providing technical support and responding to player inquiries;

  • Authenticating and verifying individual identities;

  • Protecting the safety and well-being of our users and safeguarding our rights and property;

  • Addressing technical issues and maintaining or enhancing network and information security;

  • Conducting audits, ensuring internal quality control, and taking safety precautions;

  • Preventing and prosecuting fraud, potentially illegal activities, or violations of our Terms, and enforcing our rights and those of other users;

  • Complying with the Terms;

  • Serving you content (such as advertising) that we believe may be of interest to you, and managing and delivering contextual and behavioral advertising;

  • Notifying users of updates, new products, content, or promotional offers;

  • Administering rewards, prizes, bonus funds, promotions, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;

  • Complying with our legal obligations, resolving disputes, collecting amounts owed to us, and enforcing our agreements;

  • Conducting research, including using Personal Information to create de-identified and/or aggregated data, which is not Personal Information and may be used and shared for any legally permitted purpose.

We may use technologies considered automated decision-making or profiling, but we will not do so in a way that has a legally significant impact on you unless we have your consent or are otherwise legally permitted to do so.

In addition to the above, we may use Personal Information to communicate with you and other users in a variety of ways, including responding to customer support inquiries, keeping you informed of in-game activity, sharing comments from friends, and providing information about prizes, promotions, virtual items, and in-game status. We may also send promotional messages through various methods, directly or in partnership with other parties. You may ask us to stop sending you promotional content at any time by contacting us at support@pullz.com, Attention: Pullz Privacy Compliance. Please refer to the Users Rights section for more information on opting out of promotional communications.

We may also use Personal Information for any other purposes communicated to you at the time of collection, or otherwise with your consent or as permitted by applicable law.

 

Sharing Personal Information

We may share your Personal Information among our subsidiaries.

We may also disclose or publish aggregated and analytical information - information about you and other users collectively that is not intended to identify you individually (such as users in their 40s residing in New York) - and other non-Personal Information for purposes including industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

Additionally, we may share your information (which may include Personal Information) with third parties or allow third parties to collect this information from our Services as described in this Privacy Policy.

We may share Personal Information to provide the Services as outlined in our Terms, including:

Service Providers. We work with our subsidiaries and other third-party companies to support the Services, including optimizing games, analyzing data, processing payments, enhancing the user experience, delivering promotional content and emails, and providing hosting services.

Auditors, Contractors, and Advisers. We may share information with our auditors, contractors, or other professional advisers as needed.

User Content. Content you make available - including posts in public forums - will generally be accessible to other users of the Services and, in some cases, to the general public. You should not expect that any information you post publicly will remain private or confidential, and you are required to exercise discretion when using public forums and making content available through the Services. Your username will always appear alongside your public posts. We are not responsible for events arising from the distribution of information you choose to post or share publicly. All content uploaded while using the Services is subject to our Terms.

Third-Party Promotional Content and Analytics. We may serve promotional content through our Services. When third-party advertisers or ad networks place ads in our Services, they may collect or we may share information for purposes such as:

  • Measuring the effectiveness of promotional content;

  • Tracking performance data (such as the number of ad clicks);

  • Offering you targeted promotional content to personalize your experience through behavioral advertising;

  • Conducting web analytics (such as through Google Analytics) to analyze traffic and improve user experience;

  • Collecting certain technical information (such as IP addresses, non-persistent device identifiers like IDFAs, and device identifiers);

  • Accessing your social network ID;

  • Using aggregated and/or de-identified information about you and other users; and

  • Utilizing contextual data about your gameplay (such as your level and session length).

Advertisers may collect this information using tracking technologies such as browser cookies and web beacons, and they may use one or more such technologies simultaneously. Please note that after clicking on third-party content, you may leave our hosted environment and become subject to the policies of the advertiser or third-party content provider.

Commercial Events. In the event that we consider or engage in a business transaction - such as a sale of assets, investment, financing, merger, acquisition, or IPO - we may disclose or transfer relevant information, including your Personal Information (such as account details and device data), to the entities involved. We will make reasonable efforts to notify you and other users of any such transaction prior to transferring Personal Information.

Legal Compliance. We may share Personal Information in the following circumstances:

  • When disclosure is necessary in response to lawful requests from public authorities, including for national security or law enforcement purposes, or pursuant to legal process (such as a court order, search warrant, or subpoena);

  • To satisfy applicable laws or regulations;

  • Where we believe our Services are being used for unlawful activities, in which case we may report such activity or share information with other organizations for fraud protection, credit risk reduction, and other security purposes;

  • When we have a good-faith belief that an emergency exists posing a threat to the health or safety of you, us, another person, or the general public;

  • When disclosure is necessary to protect our rights or property, or the rights or property of third parties, including to enforce our Terms.

 

Users Rights

Depending on the applicable law and your circumstances, you may have the right to make the following requests regarding certain Personal Information we process:

  • To receive information about how your Personal Information is used;

  • To be granted access to your Personal Information;

  • To correct or rectify inaccurate Personal Information;

  • To have your Personal Information erased;

  • To receive an electronic copy of your Personal Information (data portability);

  • To object to certain information processing activities.

Information We Receive from External Applications

To manage information we receive about you from external applications, you will need to follow the instructions provided by each respective third-party application to update your information and adjust your privacy settings.

You can stop sharing your geolocation with us through your device's application settings or through the settings page within the relevant game. If you have previously permitted us to access your geolocation data, we may continue to use that information as described in this Privacy Policy.

Promotional Communication - Opt Out

To stop receiving promotional communications from Pullz, you may click the "unsubscribe" link in any promotional email. To stop receiving text or SMS messages, reply "STOP" to any promotional message. Please note that it may take some time for your opt-out to take effect.

In most of our games, you may also find an option under "your account" or "Settings" to request that we stop sending you promotional communications.

Disclosures of Personal Information - Opt Out

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Pullz's processing of your Personal Information, you may withdraw that consent at any time and opt out of further processing by contacting us at support@pullz.com.

If you opt out, we may still collect and use non-personal information (such as Analytic Data) about your use of our Services for non-interest-based advertising purposes, such as evaluating the effectiveness of advertisements. We may also continue to collect, use, and share Personal Information in connection with the Services and in accordance with our rights and those of other users under the Terms.

You may opt out by following the unsubscribe instructions provided on our website. Please note that we are required to send you certain communications regarding the Services - such as updates to our Terms or this Privacy Policy - and you will not be able to opt out of those communications.

Push Notifications. We may occasionally send you push notifications with updates and information that may be of interest to you. You may opt out of these communications by adjusting the notification settings on your device.

Cookie Tracking Opt Out. You can configure your web browser to warn you before cookies are placed on your device or to limit the types of cookies you accept. Flash cookies operate differently from browser cookies, and standard browser cookie management tools may not remove them. To learn more about and manage flash cookies, please visit https://en.wikipedia.org/wiki/Local_shared_object. Please be aware that disabling cookies may affect the functionality of our Services, as certain Pullz features depend on cookies to operate.

 

International Transfers, Retention, Security, Links, Updates, and Contact Information

International Transfers

When you use our Services, your Personal Information may be transferred outside your country of residence - for example, to the United States, Europe, or Israel. We may transfer Personal Information to our subsidiaries, vendors, business partners, and others as described in this Privacy Policy. By using the Services, you consent to such transfers. Please be aware that privacy laws vary by jurisdiction, and the laws in the country to which your information is transferred may be less protective than those in your country of residence.

Retention

We will retain your Personal Information for as long as you are an active user of the Services, and thereafter for as long as needed for purposes not prohibited by applicable law. Prior to using your Personal Information for any new purpose not originally authorized by you or set forth in our Terms, we will make reasonable efforts to inform you of the new purpose and provide you the opportunity to opt out. Where consent is required by applicable law or contract to process Personal Information, we will make reasonable efforts to comply with such requirements.

Upon termination of your use of the Services, we reserve the right to retain your personal information as part of our standard backup procedures in an aggregated format. When Personal Information is no longer required, we will take appropriate steps to destroy, delete, erase, or convert it to an anonymous form.

Security

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

The security of your account also depends on your own protection of your account credentials and device. Any email or communication requesting your password or sensitive account information should be treated as unauthorized and suspicious, and should be reported to us immediately at support@pullz.com. If you share your password or device with a third party, that party will have access to your account and Personal Information, and you may be held responsible for any actions taken using your credentials. If you believe someone else has obtained access to your password, please change it immediately. If you believe an unauthorized access has already occurred, please report it immediately at support@pullz.com.

Links to Other Sites and Applications

We are not responsible for third-party content. Before interacting with any third-party content, you should review the terms and privacy policy of the applicable third party.

Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or any other privacy matter, please contact us at support@pullz.com.

To exercise your user rights, you may submit a request through the applicable support channel for the relevant game.

For California residents, Pullz can be reached by email at support@pullz.com; Attention: Pullz Privacy Compliance.

If you have concerns that you feel have not been adequately addressed, you may also have the right to contact the privacy authority in your jurisdiction.

 

Law and Jurisdiction

This Privacy Policy, and the relationship between you and Pullz (whether contractual or otherwise), shall be governed by and construed in accordance with the laws of the State of Israel. Any disputes concerning this Privacy Policy or the relationship between you and Pullz, or any matters arising therefrom or associated therewith (whether contractual or otherwise), shall be subject to the exclusive jurisdiction of the courts situated in Tel Aviv, Israel.

 

Supplemental California Consumer Privacy Act (CCPA) Policy

Pullz uses and shares information as described in this Privacy Policy. The following information supplements our Privacy Policy and is intended for California consumers only.

Under the CCPA, California residents have certain rights regarding their Personal Information. To exercise these rights on or after January 1, 2020, please contact us using the contact information provided in the "Contact Information" section below. For your privacy and security, we may require you to verify your identity before fulfilling your request, as permitted by the CCPA. We will respond to your request within the timeframe required by the CCPA.

This Policy discloses the Personal Information we collect and the purposes for which we collect it. Please refer to "Categories of Information We Collect" above. The CCPA grants you the following specific rights:

Right to Request Disclosure. Upon a verifiable request, we will disclose the following, one or more of which may be addressed by reference to this Policy:

  • The categories of Personal Information Pullz has collected about you;

  • The categories of sources from which that Personal Information was collected;

  • The business purpose for which the Personal Information was collected;

  • The categories of third parties with whom Pullz has shared the information; and

  • The specific pieces of Personal Information Pullz has collected about you.

Right to Opt Out of the Sale of Your Information. To exercise this right, please contact us at support@pullz.com.

Right to Request Deletion. Upon a verifiable request, we will - where required under the CCPA and subject to certain exceptions - delete your Personal Information from our records and direct our service providers to do the same.

We may decline to delete your Personal Information if retaining it is necessary to:

  • Complete a transaction, fulfill a warranty or product recall, provide a requested good or service, or otherwise perform a contract with you;

  • Detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible;

  • Debug and repair errors that impair existing intended functionality;

  • Exercise free speech, support another consumer's right to free speech, or exercise another legally protected right;

  • Comply with the California Electronic Communications Privacy Act;

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest, where deletion would likely impair or prevent the research, and where informed consent has been obtained;

  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

  • Comply with an existing legal obligation; or

  • Use your Personal Information internally in a lawful manner consistent with the context in which it was provided.

Right to Be Free from Discrimination. Pullz will not discriminate against you for exercising any of your rights under the CCPA.

 

What We May Need from You

To process your request, we may need to ask for specific information to verify your identity and confirm your right to access your Personal Information or exercise any other applicable rights. This is a security measure to ensure that Personal Information is not disclosed to unauthorized individuals. We may also contact you for additional information to help us respond to your request more efficiently.

 

GDPR

If the General Data Protection Regulation (GDPR) applies to you, you may be entitled to the following rights in certain circumstances:

Right to Access. You may have the right to obtain a copy of your Personal Information, along with supplementary information such as the purpose of our collection and processing activities and whether your information is shared with others.

Right of Rectification. You may have the right to have inaccurate Personal Information corrected or incomplete Personal Information completed.

Right to Erasure. You may have the right to have your Personal Information erased. We will erase Personal Information without undue delay where:

  • The Personal Information is no longer necessary for the purposes for which it was collected;

  • You withdraw consent and no other legal basis for processing exists;

  • You object to the processing and there are no overriding legitimate grounds;

  • The Personal Information has been unlawfully processed; or

  • Erasure is required to comply with a legal obligation.

Right to Restrict Processing. You may have the right to request that processing of your Personal Information be restricted.

Right to Data Portability. You may have the right to request that your Personal Information be transferred to another data controller. In certain situations, we may not have the technical capability to port the information automatically; in such cases, we will recommend that you request deletion of your Personal Information instead.

Right to Object to Processing. You may have the right to object to the collection or processing of your Personal Information if you believe it was collected or processed unlawfully.

 

Updates

We reserve the right to update this Privacy Policy from time to time, including to reflect changes in our practices regarding the collection and use of account details and device data, or to comply with applicable law. We may not always provide advance notice of such changes, and we encourage you to review this Privacy Policy regularly.

Pullz may notify you of any updates by posting a notice on our website or by sending a notice to the email address associated with your account. Your continued use of the Services following such notice constitutes your consent to and acceptance of the updated terms.

If you have any questions regarding this Privacy Policy, please contact us at support@pullz.com

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