Privacy Policy →

Support Desk

Updated September 25, 2026 00:40

FULL COLOR GAMES, INC.
GLOBAL PRIVACY POLICY
Effective Date: September 24, 2026

IMPORTANT NOTICE

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

This Privacy Policy describes how Full Color Games, Inc. ("FCGI," "Full Color Games," "we," "us," or "our") collects, uses, processes, stores, protects, discloses, retains, and otherwise handles information in connection with Full Color® Solitaire and FCGI's related games, websites, applications, products, platforms, features, services, educational products, promotional programs, multiplayer services, GameKits, PlayKits, CompetitionKits, RewardsKits, and other offerings collectively covered by this Privacy Policy (the "Service").

This Privacy Policy applies globally, subject to additional rights, restrictions, consent requirements, and other obligations imposed by the laws applicable in a particular country, state, province, territory, or other jurisdiction.

PRIVACY POLICY, TERMS OF USE, AND USER ACCEPTANCE

Your access to and use of the Service are also governed by FCGI's applicable Terms and Conditions of Use, End User License Agreement, GameKit Terms, Intellectual Property and Restricted-Use Conditions, supplemental terms, competition rules, promotion rules, school or institutional agreements, and other applicable agreements (collectively, the "Terms").

The Terms constitute the contractual agreement governing your license, access to, and use of the Service.

This Privacy Policy describes FCGI's privacy and data-processing practices and forms part of the legal notices and conditions governing the relationship between FCGI and users of the Service to the extent permitted by applicable law.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, BY DOWNLOADING, INSTALLING, ACCESSING, OPENING, LAUNCHING, REGISTERING FOR, LOGGING INTO, PLAYING, OR OTHERWISE USING THE SERVICE AFTER THIS PRIVACY POLICY AND THE APPLICABLE TERMS HAVE BEEN MADE AVAILABLE OR CONSPICUOUSLY REFERENCED TO YOU, YOU ACKNOWLEDGE THAT YOU HAVE BEEN PROVIDED ACCESS TO THIS PRIVACY POLICY AND THE APPLICABLE TERMS.

WHERE FCGI PRESENTS AN "I ACCEPT," "I AGREE," CHECKBOX, CONSENT SCREEN, DEVICE-PERMISSION REQUEST, OR OTHER AFFIRMATIVE CONTROL RELATING TO A PARTICULAR PRIVACY PRACTICE, SELECTING OR AUTHORIZING THAT CONTROL CONSTITUTES YOUR AFFIRMATIVE CHOICE, ACKNOWLEDGMENT, CONSENT, OR AUTHORIZATION TO THE EXTENT PROVIDED BY THE APPLICABLE NOTICE AND PERMITTED BY APPLICABLE LAW.

A PRIVACY POLICY ACKNOWLEDGMENT IS NOT A SUBSTITUTE FOR AFFIRMATIVE CONSENT, PARENTAL CONSENT, SCHOOL AUTHORIZATION, DEVICE PERMISSION, APP TRACKING TRANSPARENCY AUTHORIZATION, OR ANY OTHER FORM OF AUTHORIZATION WHERE APPLICABLE LAW OR PLATFORM REQUIREMENTS INDEPENDENTLY REQUIRE SUCH AUTHORIZATION.

WHERE A PARTICULAR FEATURE REQUIRES THE COLLECTION OR PROCESSING OF INFORMATION THAT CANNOT LAWFULLY OR TECHNICALLY BE PROVIDED WITHOUT YOUR CONSENT OR PERMISSION, YOU MAY DECLINE THAT CONSENT OR PERMISSION. THE AFFECTED FEATURE MAY THEN BE UNAVAILABLE.

IF YOU DO NOT AGREE TO FCGI'S APPLICABLE TERMS, DO NOT DOWNLOAD, INSTALL, ACCESS, OPEN, LAUNCH, REGISTER FOR, LOG INTO, OR USE THE AFFECTED SERVICE.

IF YOU DO NOT WISH FCGI TO PROCESS PERSONAL DATA REQUIRED FOR AN OPTIONAL FEATURE, DO NOT ENABLE OR USE THAT FEATURE.

WHERE BASIC GAMEPLAY IS AVAILABLE ANONYMOUSLY, A USER MAY CONTINUE TO USE THE PORTIONS OF THE SERVICE THAT FCGI MAKES AVAILABLE WITHOUT REGISTRATION, SUBJECT TO THE APPLICABLE TERMS AND THE LIMITED TECHNICAL PROCESSING NECESSARY TO PROVIDE, SECURE, AND MAINTAIN THE SERVICE.

CURRENT CORE PRIVACY PRACTICES

FCGI does not currently sell Personal Data.

FCGI does not sell Personal Data concerning children or students.

Basic Full Color® Solitaire gameplay does not require a user to create an FCGI account, provide an email address, or purchase a subscription.

Certain optional services require registration, authentication, verification, permissions, or additional information because those services depend upon FCGI's ability to identify or authenticate a user, preserve information on the user's behalf, prevent fraud or abuse, administer the requested service, or comply with applicable legal, contractual, platform, promotional, competition, security, or geographic requirements.

Children and students participating through authorized school or institutional programs are not required by FCGI to provide a personal email address or independently verify an email address.

FCGI seeks to collect and process only information reasonably appropriate for the applicable Service, feature, security function, legal requirement, or other purpose described in this Privacy Policy.

NO IMPLIED CONSENT WHERE LAW REQUIRES AFFIRMATIVE CONSENT

Nothing in this Privacy Policy should be interpreted to mean that FCGI relies upon continued use of the Service as consent where applicable law requires an affirmative act, verifiable parental consent, school authorization, specific consent, express consent, device permission, or another legally prescribed form of authorization.

Where consent is the applicable legal basis for processing, FCGI will obtain the consent required by applicable law.

Where processing is instead permitted on another lawful basis, including performance of a requested service, compliance with legal obligations, protection of security, prevention of fraud, or another basis recognized by applicable law, FCGI may process the applicable information without characterizing that processing as consent-based.

FCGI reserves the right to modify this Privacy Policy and its privacy practices at any time to the fullest extent permitted by applicable law. Changes may become effective upon publication or on another date designated by FCGI. Advance or individualized notice will be provided only where required by applicable law, applicable platform requirements, or an express written agreement binding upon FCGI. Where a change requires affirmative consent, authorization, permission, or an opportunity to opt out under applicable law, FCGI will provide the applicable mechanism.

CHANGES IN REQUIRED PROCESSING

FCGI may change the technologies, features, service providers, or methods used to operate the Service over time.

If FCGI introduces a materially different processing activity that requires additional notice, consent, authorization, opt-out rights, device permission, parental authorization, school authorization, or platform disclosure, FCGI will implement the applicable requirement before or in connection with that processing where required by law.

MANDATORY RIGHTS

Nothing in this Privacy Policy or FCGI's Terms waives, limits, or eliminates a privacy or consumer right that applicable law does not permit FCGI or the user to waive.

TABLE OF CONTENTS

About FCGI and Scope of This Privacy Policy
Definitions
Anonymous Play and Optional Account Registration
Information We Collect
Information You Provide Directly to FCGI
Anonymous Play, Registered Accounts, and Account-Dependent Features
Technical, Device, Session, Usage, Gameplay, and Diagnostic Information
Location Information and Location-Based Services
Device Permissions, Camera, Photo Library, Microphone, Contacts and Contact-Based Verification
Communications, Email, SMS, APNS, and Push Notifications
Multiplayer Voice Communications
Promotions, Sponsorships, Complimentary Gameplay, and Promotional Codes
GameKit, PlayKit, CompetitionKit, RewardsKit, and Related Services
Children, Students, Schools, Parents, and Guardians
User-Generated Content, Profiles, Sharing, and Public Features
Third-Party Services, Software Development Kits, and Service Providers
Apple In-App Purchases, Purchases, and Subscriptions
Cookies, Website Technologies, and Web Session Information
Analytics, Security, Fraud Prevention, and Game Integrity
IDFA and App Tracking Transparency
How FCGI Discloses Personal Data
No Sale of Personal Data
Advertising, Sponsored Content, and Tracking
Data Retention
Account and Personal Data Deletion
International Data Processing and Transfers
Privacy Rights
European Economic Area, European Union, and United Kingdom Privacy Information
United States State Privacy Rights
California Privacy Information
Other United States State Privacy Rights
Rights of Users Outside the United States
International Data Transfers
Data Retention, Educational Records, and Specialized Retention Requirements
Specialized Deletion, Return, De-Identification, and Preservation Requirements
Data Security
Legal Holds, Disputes, Fraud, and Evidentiary Preservation
Automated Processing, Fraud Detection, Game Authenticity, Contacts-Based and Other Verification
Do Not Track and Global Privacy Control
Children's Privacy Requests
Changes to Third-Party Providers and Technology
Changes to This Privacy Policy and FCGI's Privacy Practices
Third-Party Websites and Services
Privacy Policy and Terms of Service
No Transfer of Intellectual Property Rights
Contacting FCGI
Privacy Complaints
Governing Privacy Rights
Effective Date
Contact Information

1. ABOUT FCGI AND SCOPE OF THIS PRIVACY POLICY

Full Color Games, Inc. develops, publishes, operates, licenses, and supports games, gaming technologies, educational tools, multiplayer functionality, competitions, rewards systems, promotional programs, and related digital services.

Our products and services include Full Color® Solitaire and may include Full Color® GameKit, PlayKit, CompetitionKit, RewardsKit, educational products, websites, multiplayer services, promotional services, competitions, rewards programs, and other products or services made available by FCGI from time to time.

Collectively, these products, applications, websites, technologies, features, and services are referred to in this Privacy Policy as the "Service."

This Privacy Policy applies when you:

play an FCGI game;
use an FCGI mobile application;
visit or use an FCGI website;
create or maintain an FCGI account;
use an FCGI educational or institutional product;
participate in multiplayer functionality;
participate in a promotion, competition, rewards program, sponsored benefit, or other FCGI program;
use an FCGI leaderboard, achievement, analytics, or historical gameplay feature;
communicate with FCGI customer support;
receive communications from FCGI; or
otherwise interact with the Service in a manner involving information processed by FCGI.

The Service is presently distributed through the Apple App Store. FCGI may expand distribution or supported platforms in the future. If FCGI does so, FCGI may update this Privacy Policy and applicable platform disclosures as appropriate.

The Service may interact with services operated by third parties, including Apple, Amazon Web Services, Google, Firebase, Meta, OneSignal, Zendesk, content-delivery providers, and other technology or infrastructure providers.

The fact that a third-party service is used in connection with the Service does not mean that FCGI provides that third party with all information FCGI possesses about a user.

FCGI limits disclosures according to the applicable purpose, functionality, configuration, contractual relationship, legal requirements, and technical operation of the Service.

2. DEFINITIONS

For purposes of this Privacy Policy:

"Account" means an account established with or through FCGI for access to account-dependent features of the Service.

"Anonymous Play" means gameplay made available without requiring the player to establish a registered FCGI Account or provide FCGI with an email address as a condition of basic gameplay.

"Authorized Adult Account" means an account established, verified, or administered by a person who is at least 18 years of age and has authority to establish or administer the applicable account or program.

"Authorized Educational Account" means an account, program, or service established, approved, authorized, or administered by a school, school district, educational institution, or other person or organization having appropriate authority to authorize the applicable educational use.

"Child" or "Children" means a person treated as a child or minor for the applicable privacy or data-protection purpose under the law governing that person or processing activity.

"De-Identified Data" means information processed in a manner reasonably designed so that it cannot reasonably be linked to an identified or identifiable individual without the use of additional information or measures, subject to the definition imposed by applicable law.

"Educational User" means a student, teacher, administrator, school, educational institution, or other authorized participant using an FCGI educational or institutional service.

"GameKit" means a license to use our SchoolKit, InstitutionKit, SponsorKit, PartnerKit, AmbassadorKit, InfluencerKit, MarketingKit, PromotionalKit or HomeKit that is used under license pursuant to our current Terms and Conditions at the time of acceptance into our GameKit program and all subsequent changes.

"Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or can reasonably be linked directly or indirectly with an identified or identifiable individual, to the extent treated as personal data, personal information, personally identifiable information, or an equivalent concept under applicable law.

"Processing" includes collecting, accessing, recording, organizing, storing, using, analyzing, transmitting, protecting, modifying, retrieving, disclosing, deleting, de-identifying, or otherwise handling information.

"Service Provider" includes a vendor, processor, contractor, infrastructure provider, platform provider, or other entity that processes information in connection with providing services to FCGI or facilitating functionality requested by FCGI or the user.

"Student" means a person participating through an Authorized Educational Account or school or institutional use of the Service.

"User" or "you" means a person accessing or using the Service, as applicable to the context.

3. ANONYMOUS PLAY AND OPTIONAL ACCOUNT REGISTRATION

A. Anonymous Play

FCGI permits users to access and play supported basic Full Color® Solitaire gameplay anonymously.

A user does not have to create an FCGI Account, provide an email address, or purchase a subscription merely to access supported basic anonymous gameplay.

Anonymous Play is intentionally provided so that users who do not require account-dependent functionality can play without establishing a registered FCGI identity.

Anonymous Play does not necessarily mean that no technical information whatsoever is processed.

Like other networked applications, FCGI may process limited technical, device, network, security, diagnostic, or gameplay information reasonably necessary to deliver the application, establish communications, maintain security, detect malicious activity, diagnose failures, protect game integrity, or perform other functions described in this Privacy Policy.

B. Optional Account Registration

Certain features require an Account because the requested functionality depends upon FCGI's ability to authenticate the user or preserve information on the user's behalf.

Account-dependent features may include:

cloud preservation of game history;
restoration of gameplay information following loss, replacement, or change of a device;
synchronization of information;
access to expanded historical gameplay information;
expanded game analytics;
multiplayer functionality requiring authenticated participation;
competitions;
rewards;
promotional benefits;
sponsor-funded benefits;
account-based leaderboards or achievements;
security-sensitive functionality;
fraud-prevention functionality;
customer-support functionality requiring account identification; or
other features that reasonably require identification, authentication, verification, or persistent storage.

C. Verified Email

Where an FCGI consumer Account requires an email address, FCGI may require verification of that email address.

FCGI uses email verification primarily for purposes including:

account authentication;
account security;
fraud prevention;
abuse prevention;
account recovery;
restoration of gameplay or account information;
prevention of unauthorized account transfers;
enforcement of account and game rules;
protection of FCGI systems and users;
customer support;
administration of account-dependent services; and
important service or security communications.

D. No Requirement to Receive Marketing

Creating an Account does not require a user to agree to receive optional marketing communications where applicable law requires marketing choice.

Users may unsubscribe from promotional email communications as described in this Privacy Policy.

A marketing opt-out does not prevent FCGI from sending communications reasonably necessary for account verification, security, authentication, purchases, transactions, customer support, legal notices, Service administration, or other non-marketing purposes.

E. Children and School Accounts

FCGI does not require children or students participating through an Authorized Educational Account to provide FCGI with a personal email address or independently verify a personal email address.

Additional provisions governing children, students, schools, parents, and guardians appear below.

4. INFORMATION WE COLLECT

Depending upon how the Service is used, FCGI may collect or process the following categories of information:

A. Account and Identity Information

name;
first name;
last name;
abbreviated name;
initials;
screen name;
player name;
pseudonym;
Account identifier;
user identifier;
authentication information;
email address;
email-verification status; and
other profile information voluntarily supplied by the user.

B. Contact Information

Depending upon the functionality used, information voluntarily provided by the User, and Device permissions affirmatively granted by the User, FCGI may collect or process:

email address;

telephone number;

customer-support contact information;

contact information voluntarily provided directly to FCGI;

names made available through authorized Contacts access;

telephone numbers made available through authorized Contacts access;

email addresses made available through authorized Contacts access;

contact identifiers made available through authorized Contacts access;

relationship or organizational information made available through authorized Contacts access where relevant to an authorized verification purpose; and

other contact information made available through authorized Contacts functionality and reasonably necessary for the applicable authorized purpose.

Contacts information obtained through Device functionality requiring permission is collected only after the User grants the applicable Device or operating-system permission.

The purposes, restrictions and User controls applicable to Contacts information are described in Section 9.3.

C. Device and Technical Information

IP address;
device type;
device model or class;
operating-system type;
operating-system version;
application version;
installation information;
application identifiers;
vendor or device-related identifiers where applicable;
network information;
language settings;
regional settings;
session information;
timestamps;
security information;
authentication information; and
similar technical information.

FCGI does not currently access or use Apple's Identifier for Advertisers ("IDFA").

FCGI does not currently use IDFA for advertising, analytics, attribution, authentication, security, or other purposes.

FCGI does not currently use App Tracking Transparency authorization to obtain access to IDFA.

FCGI uses other technical, account, session, device, and security mechanisms to authenticate activity and protect the Service.

D. Location Information

Depending upon the feature selected by the user and permissions granted by the user, FCGI may process:

country;
state;
province;
territory;
region;
coarse or approximate location;
location inferred from an IP address or similar technical information; and
precise device location when the user affirmatively enables applicable location permission.

Precise location is not required for basic anonymous gameplay.

E. Gameplay Information

FCGI may process information concerning gameplay, including:

games played;
gameplay history;
scores;
achievements;
leaderboard information;
game identifiers;
seed identifiers;
game-state information;
gameplay events;
results;
timestamps;
duration of play or replay;
competition activity;
multiplayer activity;
player matching information;
progression information;
historical statistics;
game analytics; and
information used to authenticate the validity or integrity of gameplay.

F. Purchase and Subscription Information

FCGI may process:

purchase history;
subscription status;
entitlement status;
promotional entitlement;
subscription expiration information;
restoration information;
Apple transaction or receipt information made available to FCGI;
promotional codes;
redemption information; and
information reasonably necessary to confirm entitlement to purchased or promotional functionality.

FCGI does not directly process or store full consumer credit-card or debit-card numbers for purchases made through the application.

Current in-app purchases are processed through Apple's In-App Purchase system.

G. Analytics and Usage Information

FCGI may process:

application sessions;
session duration;
application interactions;
gameplay interactions;
product interactions;
feature usage;
analytics events;
performance information;
diagnostic information;
device-type information;
application-state information;
security events;
suspected fraud or abuse events;
authentication events; and
similar operational analytics.

H. Crash and Performance Information

FCGI may process:

crash reports;
error information;
diagnostic information;
application performance information;
device and operating-system information associated with a technical failure;
application state associated with a technical failure; and
information reasonably necessary to diagnose, reproduce, secure, or correct technical problems.

I. Notification Information

FCGI may process:

APNS or other push-notification tokens;
notification preferences;
delivery status;
notification interactions;
OneSignal identifiers;
segmentation information;
notification campaign or event information; and
information necessary to deliver authorized notifications.

J. Customer-Support Information

When a user requests support, FCGI may process:

name;
email address;
screen name;
player or Account identifier;
support-ticket information;
correspondence;
screenshots;
attachments;
voluntarily submitted photographs;
device information;
application information;
gameplay information;
transaction information;
diagnostic information; and
other information voluntarily supplied by the user to explain or resolve the support request.

K. User-Generated Content

Where supported, users may voluntarily create, submit, display, share, or publish content, including:

screen names;
profile information;
photographs;
screenshots;
comments;
messages;
gameplay information;
scores;
achievements;
leaderboard information; and
other content voluntarily submitted through an available feature.

L. School and Educational Information

For school and institutional use, FCGI may process limited identifiers selected by the school, institution, authorized adult, teacher, administrator, or other authorized participant, such as:

J. Doe;
Jane D.;
JaneD1234;
initials;
abbreviated names;
screen names;
pseudonyms;
player identifiers; or
similar minimally identifying information.

FCGI does not require a student participating through an Authorized Educational Account to provide a personal email address.

FCGI does not require a student participating through an Authorized Educational Account to independently verify a personal email address.

FCGI does not require schools to provide a student's full legal name when an abbreviated name, initials, screen name, pseudonym, or similar identifier is sufficient.

FCGI encourages schools and institutions to provide the minimum Personal Data reasonably necessary for the applicable educational purpose.

M. Educational Gameplay and Reporting Information

The Service may process educational gameplay and reporting information generated through use of FCGI educational tools, including:

games assigned;
game identifiers;
practice activity;
completion information;
scores;
performance information;
achievement information;
class or group information;
competition results;
training information;
historical performance; and
reports generated from gameplay.

Teachers, schools, or institutions may use FCGI tools to create or maintain their own educational records.

FCGI does not require schools to provide formal school transcripts, disability records, disciplinary records, government identification numbers, medical information, or other unrelated formal education records in order to use the Service.

N. Promotion, Competition, and Rewards Information

Where applicable, FCGI may process information concerning:

promotional codes;
code redemption;
complimentary gameplay;
complimentary subscriptions;
sponsored benefits;
eligibility;
participation;
competition entry or participation;
competition results;
rewards;
achievements;
geographic eligibility;
fraud-prevention information;
duplicate-redemption prevention;
entitlement status; and
information reasonably necessary to administer the applicable promotion, competition, reward, or benefit.

O. Information FCGI Does Not Intentionally Collect as Part of Its Ordinary Service

FCGI does not intentionally require or collect as part of ordinary gameplay:

Social Security numbers;
equivalent national identification numbers;
government-issued identification numbers;
bank-account credentials;
full consumer payment-card numbers;
biometric identifiers for identification purposes;
health or medical information;
disability information;
school transcripts; or
disciplinary records.

Users should not submit such information to FCGI unless FCGI specifically requests particular information for a lawful and disclosed purpose.

5. INFORMATION YOU PROVIDE DIRECTLY TO FCGI

Information provided directly to FCGI may include information submitted when a user:

creates an Account;
verifies an Account;
updates a profile;
selects a screen name;
requests customer support;
communicates with FCGI;
subscribes to news or marketing communications;
participates in an optional promotion;
redeems a promotional code;
participates in a competition or rewards program;
uploads or selects a custom game background;
submits content;
participates in an educational or institutional program;
requests account restoration;
requests access to historical gameplay information.

6. ANONYMOUS PLAY, REGISTERED ACCOUNTS, AND ACCOUNT-DEPENDENT FEATURES

FCGI permits users to access and play supported portions of Full Color® Solitaire without creating an FCGI account.

A user may play the basic game anonymously without:

creating an FCGI account;
providing FCGI with a name;
providing FCGI with an email address;
verifying an email address;
subscribing to a paid service; or
agreeing to receive marketing communications.

Anonymous play may nevertheless involve limited technical information reasonably necessary to operate, secure, maintain, diagnose, and protect the Service as described elsewhere in this Privacy Policy.

Certain optional features require an FCGI account because FCGI must be able to authenticate the user, maintain information on the user's behalf, restore information, administer the applicable feature, prevent fraud or abuse, or comply with applicable legal, contractual, platform, competition, promotional, or security requirements.

Account-dependent functionality may include:

cloud storage of gameplay information;
restoration of gameplay information following loss, replacement, or change of device;
synchronization of gameplay information;
expanded gameplay history;
historical analytics;
account-specific preferences;
multiplayer functionality;
competitions;
rewards;
promotions;
promotional-code redemption;
complimentary or sponsored gameplay;
subscription functionality;
account-linked achievements;
enhanced leaderboard functionality;
security-sensitive features;
school or institutional functionality where an individual registered account is appropriate;
customer-support functionality requiring account verification; and
other features that reasonably require authentication or persistent account information.

A user's decision not to create an account does not prevent the user from using portions of the Service that FCGI makes available for anonymous play.

Certain account-dependent functions may be unavailable to anonymous users because FCGI cannot reliably restore, synchronize, authenticate, administer, secure, or associate those functions without an account.

6.1 ACCOUNT REGISTRATION

Where a user elects to create an FCGI consumer account, FCGI may request information reasonably necessary to create, authenticate, maintain, secure, and support the account.

Depending upon the registration method selected by the user, this information may include:

name;
email address;
screen name;
password or other authentication information;
FCGI account or user identifier;
account preferences;
supported third-party authentication information; and
other information voluntarily entered into the user's account or profile.

FCGI requires a verified email address for ordinary registered consumer accounts where email verification is used as part of FCGI's authentication, fraud-prevention, security, abuse-prevention, account-recovery, or account-restoration systems.

The primary purposes of account verification include:

confirming that an account can be associated with a legitimate user;
reducing fraudulent account creation;
preventing account theft;
preventing abuse;
preventing repeated unauthorized promotional redemption;
protecting cloud-saved gameplay;
restoring account information;
providing account recovery;
securing multiplayer or other account-dependent functionality;
investigating suspicious activity; and
maintaining the integrity of the Service.

Creating an FCGI account does not require a user to consent to unrelated advertising or marketing processing where such processing requires separate consent under applicable law.

6.2 OPTIONAL THIRD-PARTY LOGIN

FCGI may permit users to create or access an account through supported third-party authentication functionality, including Sign in with Apple or Facebook login.

Use of a supported third-party login method is optional unless expressly disclosed for a particular feature.

A user who chooses a third-party authentication method authorizes the applicable provider to provide FCGI with the information necessary to complete the authentication process according to the user's settings, permissions, the provider's functionality, and applicable law.

FCGI does not require a user to maintain a Facebook account merely to play the basic game.

The applicable third-party authentication provider may independently process information under its own terms and privacy practices.

6.3 ACCOUNT VERIFICATION DOES NOT REQUIRE MARKETING CONSENT

FCGI may require account verification where reasonably necessary to provide or protect an account-dependent Service.

Account verification is separate from consent to receive promotional marketing communications.

A user may opt out of promotional email communications without thereby disabling necessary transactional, account, security, support, purchase, verification, legal, or service communications.

Where SMS marketing or another marketing channel requires separate consent under applicable law, FCGI will obtain the applicable consent separately.

FCGI does not condition ordinary anonymous gameplay upon a user's agreement to receive marketing communications.

6.4 ACCOUNT RESTORATION AND CLOUD-SAVED DATA

Registered users may elect to use functionality that allows FCGI to maintain gameplay or account information so that the information may be restored following loss, replacement, corruption, reset, or change of device.

FCGI may maintain information reasonably necessary to provide such functionality, including:

account identifiers;
gameplay history;
scores;
achievements;
game or seed identifiers;
purchases or entitlements;
subscription status;
settings;
preferences;
historical analytics;
account restoration information; and
other account-dependent data selected or generated through use of the applicable feature.

These services require persistent storage and may involve FCGI's cloud infrastructure because the requested information cannot be restored from FCGI's systems if FCGI does not maintain it.

6.5 SCHOOL AND INSTITUTIONAL PARTICIPATION DOES NOT REQUIRE CHILD EMAIL REGISTRATION

Children or students participating through an authorized school, educational institution, or other authorized institutional program are not required by FCGI to create an ordinary consumer account or provide FCGI with a personal email address merely to participate in the applicable authorized program.

The additional provisions governing children, students, schools, parents, guardians, and institutional use appear elsewhere in this Privacy Policy.

7. TECHNICAL, DEVICE, SESSION, USAGE, GAMEPLAY, AND DIAGNOSTIC INFORMATION

When a user accesses or uses the Service, FCGI may automatically collect, generate, receive, or process limited technical and operational information reasonably necessary to provide, secure, authenticate, maintain, diagnose, analyze, and improve the Service.

Depending upon the feature used, device, operating system, permissions, account status, and technical environment, this information may include:

IP address;
device model or device class;
operating-system type and version;
application version;
browser type where applicable;
language or regional settings;
network information;
application installation information;
vendor, application, installation, or other technical identifiers;
session identifiers;
session start and end information;
session duration;
game-session information;
gameplay history;
game or seed identifiers;
scores;
achievements;
leaderboard activity;
competition activity;
redemption activity;
purchase or subscription status;
product interaction information;
application events;
crash information;
diagnostic information;
performance information;
error logs;
security events;
authentication events;
fraud indicators;
abuse indicators;
location-related information where permitted and applicable;
push-notification identifiers or tokens;
technical analytics events; and
other comparable operational information reasonably necessary to provide or protect the Service.

FCGI may associate some technical or gameplay information with a registered account where association is reasonably necessary to provide requested account-dependent functionality, restore user information, maintain game history, authenticate gameplay, prevent fraud, administer competitions, maintain leaderboards or achievements, provide customer support, or protect the Service.

Information associated only with anonymous gameplay may remain unassociated with an identified FCGI consumer account unless the user later chooses to register or otherwise causes the information to become associated with an account through supported functionality.

7.1 DEVICE INFORMATION

FCGI may process information identifying the general technical characteristics of a device.

For example, FCGI may determine that the user is accessing the Service from a particular model or class of Apple device, such as an iPhone model, together with the operating-system version and application version.

FCGI uses device information for purposes including:

application compatibility;
security;
fraud prevention;
account protection;
gameplay authentication;
troubleshooting;
performance analysis;
crash diagnosis;
customer support;
identifying abnormal activity;
detecting unauthorized modifications;
verifying legitimate game sessions; and
improving the Service.

FCGI does not currently access or use Apple's Identifier for Advertisers ("IDFA"), as further described in this Privacy Policy.

7.2 SESSION AND USAGE INFORMATION

FCGI may process session and usage information to understand and protect activity occurring through the Service.

This may include information concerning:

when a session begins;
when a session ends;
duration of a session;
game state;
games started or completed;
game or seed identifiers;
interactions with game functionality;
scores;
achievements;
leaderboard activity;
competition activity;
redemption events;
technical errors;
authentication events;
suspicious activity; and
other operational events associated with use of the Service.

FCGI uses this information for operational analytics, gameplay authenticity, security, anti-fraud purposes, abuse prevention, performance evaluation, debugging, product improvement, educational functionality, and other purposes described in this Privacy Policy.

7.3 GAMEPLAY AUTHENTICITY, SECURITY, AND ANTI-MANIPULATION

FCGI may process technical, session, device, network, account, gameplay, and related information to authenticate gameplay and protect the integrity of game results.

FCGI may use such information to detect, investigate, prevent, or respond to:

cheating;
leaderboard manipulation;
achievement manipulation;
score manipulation;
unauthorized alteration of game state;
unauthorized account access;
account theft;
fraudulent account creation;
duplicate or unauthorized promotional redemption;
automated activity;
bots;
circumvention of game limitations;
manipulation of geographic restrictions;
unauthorized modification of the application;
attempted database manipulation;
SQL or other injection attacks;
exploitation of vulnerabilities;
tampering with network communications;
unauthorized access to FCGI systems;
suspicious session behavior;
abuse of competitions or rewards; and

other activity that threatens FCGI, its users, its games, its systems, its schools, its sponsors, or the integrity of the Service.

FCGI may compare information across legitimate account, device, network, session, gameplay, security, or location signals where reasonably necessary to identify inconsistencies associated with fraud, abuse, cheating, manipulation, or unauthorized access.

7.4 CRASH, PERFORMANCE, AND DIAGNOSTIC INFORMATION

FCGI may process crash reports, diagnostic events, application-performance information, technical errors, device information, operating-system information, and related technical information to identify and correct problems affecting the Service.

FCGI may use limited third-party diagnostic and performance services for these purposes, as further described in the Third-Party Services, Software Development Kits, and Service Providers section of this Privacy Policy.

7.5 PUSH-NOTIFICATION AND COMMUNICATION IDENTIFIERS

Where a user enables supported push-notification functionality, FCGI or its service providers may process APNS tokens, OneSignal identifiers, device or application identifiers, segmentation information, or similar technical information reasonably necessary to deliver, secure, administer, analyze, or verify the applicable notification.

Such information may be used for:

security notifications;
account notifications;
multiplayer events;
competitions;
educational activities;
school assignments;
scheduled practice or training;
scoring events;
promotions;
promotional-code delivery;
complimentary gameplay;
sponsor-funded benefits;
rewards; and
other authorized Service communications.

7.6 ANALYTICS DOES NOT MEAN SALE OF PERSONAL DATA

FCGI's collection and use of technical, gameplay, device, session, diagnostic, performance, and security information for its own analytics, security, game integrity, fraud prevention, product improvement, educational functionality, and other internal purposes does not mean that FCGI sells that information.

FCGI does not currently sell Personal Data.

FCGI does not currently provide user-supplied FCGI registration information to third-party advertising networks for their independent cross-context behavioral advertising.

Third-party service providers may process limited technical information where necessary to provide the specific service for which FCGI uses them, as described elsewhere in this Privacy Policy.

7.7 TECHNICAL INFORMATION FROM ANONYMOUS USERS

Anonymous play does not mean that no technical information whatsoever is processed.

Even where a player has not created an FCGI account, FCGI may process limited device, network, session, gameplay, diagnostic, performance, security, fraud-prevention, and similar technical information reasonably necessary to:

deliver the game;
maintain a session;
protect the Service;
prevent abuse;
detect attacks;
validate gameplay;
diagnose errors;
preserve application integrity;
enforce game limitations;
provide anonymous gameplay functionality; and
comply with applicable law or platform requirements.

FCGI does not require an anonymous user to provide a name or email address merely to permit this technical processing necessary to provide and protect anonymous gameplay.

7.8 INFORMATION LINKED TO A REGISTERED USER

Where a user creates an FCGI account, certain gameplay, device, session, purchase, subscription, security, competition, reward, promotion, support, or technical information may be associated with that user's account where reasonably necessary to provide the applicable account-dependent Service.

Association with an account may be necessary to:

restore gameplay information;
maintain historical game data;
display user analytics;
maintain account-linked scores or achievements;
administer purchases or subscriptions;
administer multiplayer functionality;
administer promotions, competitions, or rewards;
detect account compromise;
prevent fraud;
investigate disputes;
provide customer support;
enforce eligibility limits; or
protect FCGI's systems and other users.

FCGI does not associate technical information with a user's identity merely for unrelated commercial profiling where FCGI has no legitimate operational purpose for doing so.

8. LOCATION INFORMATION AND LOCATION-BASED SERVICES

FCGI may collect or process location information where reasonably necessary to provide a feature requested by the user, protect the Service, determine geographic eligibility, comply with applicable restrictions, or perform another purpose described in this Privacy Policy.

Depending upon the feature, device, operating system, permissions selected by the user, and technical method used, location information may include:

country, state, province, region, or similar geographic information;
approximate or coarse location derived from an IP address, network information, device information, or another permitted source; or
precise location where the user affirmatively permits the Service to access precise device location and such information is necessary or appropriate for the requested feature.

FCGI does not require a user to enable precise device location merely to play the basic game anonymously.

Where FCGI requests access to device Location Services, the user may accept or decline the request through the controls provided by the user's device or operating system.

A user's decision not to provide optional location information may prevent FCGI from providing a particular location-dependent feature. It does not, by itself, prevent the user from accessing portions of the Service that do not require that information.

8.1 MULTIPLAYER MATCHING AND JURISDICTIONAL CONTROLS

FCGI may use location information to facilitate multiplayer functionality and determine whether particular multiplayer activity is permitted or available in the player's location.

FCGI may use location information to:

identify the country, state, province, region, or other jurisdiction from which a player accesses the Service;
match players for multiplayer games;
connect players who elect to participate in multiplayer functionality;
prevent prohibited or restricted cross-border or cross-jurisdictional play;
comply with geographic, legal, regulatory, contractual, competition, promotional, or platform restrictions;
promote fair and equitable gameplay;
detect location manipulation, fraud, circumvention, cheating, or abuse; and
authenticate or cross-check information used to protect game and competition integrity.

Certain multiplayer features may be unavailable if FCGI cannot determine the geographic information reasonably necessary to provide the feature lawfully or securely.

8.2 PROMOTIONS, SPONSORSHIPS, AND LOCATION

FCGI may use location information to determine eligibility for geographically limited:

promotional codes;
complimentary gameplay;
complimentary subscriptions;
sponsor-funded benefits;
competitions;
rewards;
educational programs;
advertisements or sponsored content;
promotional events; or
other offers or opportunities.

FCGI may determine that a particular promotion or sponsored benefit is available in one geographic area and unavailable in another.

FCGI seeks to use only the degree of location precision reasonably necessary to make the applicable determination.

A sponsor's funding of an advertisement, promotion, complimentary subscription, promotional code, competition, reward, educational program, or other benefit does not, by itself, entitle the sponsor to receive the user's Personal Data.

9. DEVICE PERMISSIONS

Certain optional features require access to functionality controlled by the user's device or operating system.

FCGI requests such access where necessary or appropriate for the user-selected feature and where required by the applicable operating system.

Users may generally control these permissions through their device settings.

9.1 CAMERA AND PHOTO LIBRARY

FCGI may request access to a user's camera or photo library when the user elects to use features that require such access.

For example, FCGI may permit registered users to select or create customized game backgrounds using photographs or images chosen by the user.

A user who does not wish to provide camera or photo-library access may decline the applicable permission. Features requiring that permission may then be unavailable.

FCGI does not require camera or photo-library access merely to play the basic game.

9.2 MICROPHONE

FCGI may request microphone access when a user elects to participate in supported real-time multiplayer voice communications.

Microphone access is not required merely to play the basic game.

The user's device or operating system may permit microphone permission to be disabled at any time. Disabling the permission will prevent functionality that requires microphone access.

9.3 CONTACTS AND CONTACT-BASED VERIFICATION

FCGI may request permission to access contact information made available through the Contacts functionality of a User's Device where Contacts access is reasonably necessary or appropriate for an authorized verification, authentication, eligibility, security, fraud-prevention, program-integrity, administrative, invitation, communication, or other functionality described in this Privacy Policy.

FCGI does not obtain access to Contacts through Device functionality requiring permission unless the User grants the applicable permission through the Device or operating-system permission controls.

Depending upon the permission granted by the User, the functionality provided by the Device or operating system, and the purpose for which Contacts access is requested, information made available to FCGI may include:

(a) names;
(b) telephone numbers;
(c) email addresses;
(d) contact identifiers;
(e) relationship or organizational information made available through the applicable Contacts functionality; and
(f) other contact information reasonably necessary for the authorized purpose.

FCGI may use permitted Contacts information for purposes including:

(a) verifying information provided by the User;
(b) verifying or authenticating an Account;
(c) evaluating or verifying a Game Kit application;
(d) determining or verifying eligibility for a Game Kit or other FCS Service;
(e) verifying an asserted personal, professional, educational, organizational or other relationship relevant to an application or Service;
(f) verifying a User's asserted authority to act for a school, institution, business, organization or other person;
(g) evaluating the authenticity or integrity of an Account, application or request;
(h) detecting or investigating suspected fraud, impersonation, abuse or circumvention;
(i) detecting duplicate, fraudulent or unauthorized Accounts or applications;
(j) protecting the security and integrity of the Service; and
(k) another verification, authentication, security, eligibility, fraud-prevention, program-integrity or administrative purpose reasonably necessary to provide, protect or administer the applicable FCS Service.

FCGI may compare information made available through authorized Contacts access with information supplied by the User or other information lawfully available to FCGI where reasonably necessary for an authorized purpose described above.

CONTACTS ACCESS AND USER CONTROL

The User controls whether FCGI receives access to Contacts through the applicable Device or operating-system permission controls.

Depending upon the functionality provided by the Device or operating system, a User may:

(a) deny Contacts access;
(b) permit limited Contacts access;
(c) select particular Contacts to make available;
(d) permit broader Contacts access;
(e) modify previously granted Contacts access; or
(f) revoke Contacts access.

Denying, limiting or revoking Contacts access may prevent FCGI from using Contacts-based functionality.

Where reasonably practicable, FCGI may provide or require another verification method where Contacts access is unavailable, denied, restricted or insufficient.

CONTACTS ACCESS DOES NOT GUARANTEE APPROVAL

Granting FCGI access to Contacts does not guarantee approval of:

(a) an Account;
(b) a Game Kit application;
(c) Game Kit eligibility;
(d) a verification request;
(e) an asserted affiliation or relationship; or
(f) any other application, entitlement, Service or request.

FCGI may determine that information available through Contacts is insufficient, inconsistent, inconclusive or otherwise inadequate for the applicable verification purpose.

FCGI may request additional verification or use another lawful verification method where appropriate.

NO CONTACT DATABASE FOR UNRELATED PURPOSES

FCGI does not use Contacts information obtained through Apple's Contacts functionality to create or maintain an independent contact database for advertising, marketing, sale, distribution to third parties or another purpose unrelated to the authorized functionality for which Contacts access was obtained.

FCGI does not sell Contacts information obtained through Device Contacts functionality.

FCGI does not provide Contacts information obtained through Device Contacts functionality to sponsors, advertisers, promoters, Game Kit licensees or other third parties for their independent advertising, marketing or commercial profiling merely because the User participates in an FCGI Service, Game Kit, promotion, Competition, Reward or sponsored program.

NO UNAUTHORIZED CONTACTING OF CONTACTS

FCGI will not independently contact a person identified through a User's Contacts merely because FCGI obtained access to that person's contact information through the User's Device Contacts.

Where FCGI provides functionality allowing a User to initiate an invitation, message or other communication to another person using Contacts information, the communication will be initiated only through User-directed functionality and subject to applicable platform requirements and applicable law.

Where required by applicable platform requirements, the User will be provided with information concerning the communication before it is sent, including the substance of the communication and the identity of the apparent sender.

FCGI will not automatically select all Contacts or default to selection of all Contacts for User-initiated communications.

RETENTION OF CONTACTS INFORMATION

FCGI will retain identifiable Contacts information only for as long as reasonably necessary for the authorized purpose for which the information was collected or another compatible lawful purpose described in this Privacy Policy, subject to applicable law and applicable platform requirements.

Retention may be appropriate where reasonably necessary for:

(a) completing or documenting an applicable verification;
(b) Account security;
(c) fraud prevention;
(d) investigation of impersonation, abuse or circumvention;
(e) Game Kit application or eligibility administration;
(f) dispute resolution;
(g) compliance with applicable law;
(h) establishment, exercise or defense of legal claims; or
(i) another lawful purpose described in this Privacy Policy.

Where continued retention of identifiable Contacts information is no longer reasonably necessary or otherwise permitted, FCGI may delete, de-identify, aggregate, dissociate or otherwise appropriately process the information in accordance with this Privacy Policy and applicable law.

SERVICE PROVIDERS

FCGI may use authorized Service Providers to process Contacts information on FCGI's behalf where reasonably necessary to provide an authorized function described in this Privacy Policy.

FCGI does not authorize a Service Provider acting on FCGI's behalf to use Contacts information obtained through FCGI for the provider's unrelated advertising, marketing, sale, commercial profiling or other independent commercial purposes.

CHILDREN AND STUDENTS

FCGI will not use Contacts access through School Kit or another child-directed or school-authorized Service to circumvent the heightened privacy protections applicable to children or students.

Where Contacts information concerns a child or student, FCGI will process that information subject to applicable children's privacy, student privacy and educational privacy requirements, including the specialized provisions of Section 14 where applicable.

CHANGES IN CONTACTS USE

If FCGI materially expands the purposes for which Contacts information is collected, used or disclosed, FCGI will provide any additional notice, consent, permission, platform disclosure or other procedure required by applicable law or applicable platform requirements before implementing the materially different processing.

10. COMMUNICATIONS, EMAIL, SMS, APNS, AND PUSH NOTIFICATIONS

FCGI may communicate with registered users through email, SMS, Apple Push Notification Service ("APNS"), in-app communications, or other supported communications technologies.

10.1 ACCOUNT AND SERVICE COMMUNICATIONS

FCGI may send communications reasonably necessary to operate, protect, authenticate, administer, or support an account or requested Service.

These communications may include:

email verification;
account authentication;
password or account-recovery communications;
security alerts;
suspected-fraud or abuse notices;
additional identity or device verification;
purchase or subscription information;
customer-support communications;
important changes affecting an account or Service;
multiplayer or competition administration;
school or institutional program communications; and
other non-marketing communications reasonably necessary to provide a requested service.

A marketing opt-out does not prevent FCGI from sending necessary transactional, account, security, legal, or service communications.

10.2 SMS VERIFICATION AND TRANSACTIONAL COMMUNICATIONS

Where a User voluntarily provides a telephone number to FCGI in connection with Account creation, Account verification, Account security, a Game Kit application, Game Kit verification or another FCS Service requiring telephone-number verification, FCGI may use that telephone number to provide the verification, authentication, security or transactional communications disclosed to the User when the telephone number is provided.

Such communications may include:

(a) one-time passwords or verification codes;
(b) Account authentication messages;
(c) telephone-number verification messages;
(d) Account security alerts;
(e) fraud-prevention or suspicious-activity verification;
(f) Game Kit application or eligibility verification;
(g) identity, affiliation or authority verification; and
(h) other transactional or security communications reasonably necessary to authenticate, verify, protect or administer the applicable Account, application or FCS Service.

Where disclosed at the point the telephone number is provided, submission of the telephone number constitutes the User's request and consent to receive the disclosed transactional or verification text messages at that telephone number to the extent permitted by applicable law.

Message and data rates may apply.

FCGI may use third-party communications and messaging Service Providers, including OneSignal or other authorized providers, to transmit SMS, MMS, verification codes, security communications and other authorized communications on FCGI's behalf.

Providing a telephone number for verification does not, by itself, constitute consent to receive unrelated promotional or marketing SMS communications.

Consent to promotional or marketing SMS communications will be obtained separately where required by applicable law, applicable carrier requirements or applicable messaging-provider requirements.

Users may reply STOP to applicable SMS communications where the applicable messaging program supports or requires that functionality.

Withdrawal from promotional or marketing SMS communications does not prevent FCGI from using another legally permissible communication method for essential Account, security, verification, transactional or Service communications.

10.3 PUSH NOTIFICATIONS AND APNS

With applicable permission, FCGI may use APNS, OneSignal, or other supported technologies to send push notifications.

Push notifications may be used for:

account or security notices;
game notifications;
multiplayer events;
competitions;
promotions;
rewards;
complimentary gameplay;
sponsor-funded benefits;
educational events;
scheduled school or classroom activities;
training sessions;
scoring events;
game assignments; or
other Service functionality.

For example, an authorized school or teacher may use supported functionality to notify participating players that a designated game, seed, exercise, practice session, test, or scoring event is beginning.

A notification may cause the Service to open or prepare the designated game or activity, subject to the applicable device and application functionality.

Users may control push-notification permissions through the settings provided by their device or operating system.

11. MULTIPLAYER VOICE COMMUNICATIONS

Certain multiplayer game modes may permit participating players to communicate through real-time voice functionality made available in connection with Apple Game Center or other supported multiplayer services.

FCGI does not record the content of those multiplayer voice communications.

FCGI does not retain the content of those multiplayer voice communications.

FCGI does not transcribe the content of those multiplayer voice communications.

FCGI does not analyze the content of those multiplayer voice communications for artificial-intelligence or machine-learning purposes.

FCGI does not use the content of those multiplayer voice communications to train artificial-intelligence or machine-learning systems.

The functionality is intended to permit real-time communication between participating players during the applicable multiplayer communication session.

The voice communication functionality terminates when the applicable multiplayer communication session ends.

Apple Game Center and other third-party platform functionality may also be subject to the platform provider's own terms, privacy policy, security practices, and technical processing.

12. PROMOTIONS, SPONSORSHIPS, COMPLIMENTARY GAMEPLAY, AND PROMOTIONAL CODES

FCGI may provide users with:

free gameplay;
complimentary subscriptions;
promotional codes;
sponsored access;
promotional benefits;
competitions;
rewards;
educational benefits;
sponsor-funded gameplay; or
other complimentary or promotional features.

Unless expressly disclosed for a particular promotion, users are not required to provide additional Personal Data, consent to unrelated tracking, subscribe to marketing communications, or authorize disclosure of their FCGI account information to a sponsor as consideration for receiving ordinary promotional gameplay or access.

FCGI may require registration, authentication, eligibility verification, or other reasonable controls where necessary to prevent repeated unauthorized redemption, fraud, abuse, circumvention of promotion limits, or other misuse.

12.1 SPONSOR BRANDING

Certain complimentary or promotional gameplay may be sponsored by a third party.

Where a user voluntarily redeems a sponsor-funded promotional code, benefit, subscription, or other offer, the applicable gameplay or user experience may display branding approved by FCGI.

For example, a game background may temporarily display the sponsor's approved name, trademark, image, likeness, promotional material, or other branding as part of the sponsored experience.

The presence of sponsor branding does not, by itself, mean that FCGI has disclosed the player's Personal Data to the sponsor.

A sponsor does not acquire a right to FCGI account information merely because the sponsor funds the applicable gameplay, promotion, competition, reward, subscription, educational program, or other benefit.

12.2 PROMOTIONAL LIMITS AND FRAUD PREVENTION

Promotions may be subject to eligibility rules, redemption limits, expiration dates, geographic restrictions, account requirements, device restrictions, competition rules, sponsor restrictions, or other disclosed conditions.

FCGI may process account, device, session, geographic, gameplay, redemption, and security information reasonably necessary to enforce those restrictions and prevent fraud or abuse.

A user who has exhausted or redeemed a particular promotional benefit is not entitled to circumvent the applicable restriction by creating duplicate accounts, manipulating devices, altering identifiers, falsifying location information, or using another method prohibited by FCGI's applicable rules or Terms.

13. GAMEKIT, PLAY KIT, COMPETITIONKIT, REWARDSKIT, AND RELATED SERVICES

FCGI may provide products, services, features, programs, or functionality known as GameKit, PlayKit, CompetitionKit, RewardsKit, or other FCGI programs.

Depending upon the applicable program, these services may support:

gameplay;
education;
instruction;
training;
practice;
competitions;
scoring;
achievements;
leaderboards;
rewards;
sponsored benefits;
promotions;
institutional programs;
classroom activities; or
other authorized activities.

The information processed depends upon the particular program and how the authorized user, school, institution, partner, sponsor, promoter, or administrator configures or uses it.

Nothing in this Privacy Policy authorizes a third party to use FCGI Personal Data for purposes inconsistent with this Privacy Policy merely because that third party participates in, sponsors, administers, or supports an FCGI program.

14. CHILDREN, STUDENTS, SCHOOLS, PARENTS, AND GUARDIANS

Full Color® Solitaire is a casual card game that may be used by adults, families, children, schools, educators, institutions, and students.

FCGI recognizes that children and students are entitled to heightened privacy protections.

FCGI therefore distinguishes ordinary consumer accounts from school-authorized or institutionally authorized participation.

14.1 SCHOOL AND INSTITUTIONAL PARTICIPATION

FCGI permits schools, educational institutions, and other authorized organizations to use applicable FCGI services for educational, instructional, training, recreational, competition, or other authorized purposes.

Access to applicable school or institutional services is established or administered through an authorized adult who is at least 18 years old or through an authorized school, educational institution, or other properly authorized administrator.

Where applicable law requires authorization from a parent, legal guardian, school, school district, educational institution, or another legally authorized person before particular Personal Data concerning a child may be collected or processed, FCGI will require the applicable authorization or limit processing to activities otherwise permitted by applicable law.

A child's acceptance of this Privacy Policy or FCGI's Terms does not substitute for parental, guardian, school, institutional, or other authorization where such authorization is independently required by applicable law.

14.2 NO STUDENT EMAIL REQUIREMENT FOR AUTHORIZED EDUCATIONAL PARTICIPATION

FCGI does not require a child or student participating through an authorized school or institutional program to:

provide FCGI with a personal email address;
verify a personal email address;
independently create a consumer FCGI account; or
provide personal contact information merely to participate through the authorized school or institutional service.

The applicable school, institution, teacher, administrator, or authorized adult may instead assign or enter an identifier sufficient to administer the applicable program.

14.3 STUDENT DATA MINIMIZATION

FCGI does not require a student's full legal name where an abbreviated name, initials, screen name, pseudonym, player name, or other minimally identifying identifier is sufficient for the applicable educational or institutional purpose.

For example, a school or authorized administrator may identify a participating student as:

J. Doe

Jane D.

Janie12345

or by another abbreviated or pseudonymous identifier.

FCGI encourages schools, institutions, educators, and administrators to provide only the information reasonably necessary to use the applicable Service.

Schools and institutions should not provide unnecessary student information such as personal email addresses, home addresses, telephone numbers, precise location, dates of birth, government identification numbers, health information, disability information, or similar information unless expressly requested by FCGI for a disclosed and legally permissible purpose.

14.4 SCHOOL RECORDS AND EDUCATIONAL INFORMATION

FCGI does not require schools to provide FCGI with school transcripts, formal academic records, disability records, disciplinary records, health records, or similar sensitive educational records in order to provide ordinary FCGI educational functionality.

Schools and educators may use FCGI functionality to create, maintain, analyze, or report gameplay-based scores, assignments, practice results, assessments, grades, rankings, progress information, or other educational information for their own authorized educational purposes.

Where such information is maintained through the Service, FCGI processes it to provide the applicable functionality and does not acquire ownership of the school's underlying educational records merely by providing the technology used to process or store them.

14.5 EDUCATIONAL ANALYTICS AND AGGREGATED INFORMATION

FCGI may use aggregated, statistical, anonymized, or de-identified information derived from educational use to understand and improve its games, educational tools, training methods, curriculum-support functionality, scoring systems, products, and services.

For example, FCGI may analyze or report that participants within a particular grade level, age grouping, class type, curriculum, training method, or other appropriately defined group achieved a particular average score or demonstrated a particular improvement after using an educational feature.

FCGI seeks to structure such aggregated or de-identified reporting so that it does not identify an individual child or student.

FCGI may use aggregated or de-identified information for research, statistical analysis, product development, performance evaluation, educational analysis, benchmarking, and improvement of FCGI products and services, subject to applicable law.

14.6 STUDENT INFORMATION AND THIRD-PARTY SERVICES

FCGI does not provide student names, abbreviated names, initials, screen names, pseudonyms, or student identifiers entered by a school or educational institution to third-party SDK providers for the provider's unrelated advertising, marketing, profiling, sale, or other unrelated commercial purposes.

Limited technical information may nevertheless be processed through service providers where reasonably necessary to provide, secure, maintain, diagnose, communicate with, or support the Service, subject to applicable law and the heightened protections applicable to children and students.

FCGI does not treat authorization provided by a school or educational institution as authorization to use student Personal Data for an unrelated commercial purpose.

14.7 ADVERTISING AND STUDENT DATA

FCGI does not sell children's or students' Personal Data.

FCGI does not use Personal Data collected from children or students through school-authorized educational use for behavioral advertising, cross-context behavioral advertising, unrelated commercial profiling, or another unrelated commercial purpose where prohibited by applicable law.

A sponsor's funding of an educational program, promotional code, complimentary subscription, competition, reward, or other benefit does not itself authorize disclosure of student Personal Data to the sponsor.

14.8 PARENT, GUARDIAN, AND SCHOOL REQUESTS

Parents, legal guardians, schools, educational institutions, and other persons having appropriate legal authority may submit written requests concerning Personal Data associated with a child or student where applicable law provides such rights.

Depending upon applicable law and the requester's authority, these rights may include access, correction, deletion, restriction, or other legally recognized privacy rights.

Requests may be submitted to:

privacy@fullcolorgames.com

FCGI may take reasonable measures to verify the identity and authority of the requester before disclosing, modifying, restricting, or deleting information concerning a child or student.

14.9 SCHOOL ACCOUNT AND STUDENT IDENTIFIER DELETION

An authorized school or institution may request deletion of information associated with its account or participating students, subject to applicable law and legitimate retention requirements.

Deletion does not necessarily require destruction of every historical game, scoring, achievement, educational, competition, security, or statistical record.

Where necessary to preserve legitimate educational reporting, grades, game history, scoring systems, leaderboards, achievements, competition integrity, fraud prevention, security, or other lawful records, FCGI or the applicable school may retain an abbreviated, pseudonymous, de-identified, or otherwise appropriately limited historical identifier such as "J. Doe," "Jane D.," or "JaneD1234."

Where reasonably practicable, directly identifying information that is no longer necessary will be deleted, de-identified, or dissociated from retained historical information.

Nothing in this section limits a deletion right that applicable law requires FCGI to honor without the applicable retention.

14.10 FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT ("FERPA")

FCGI has designed its school and institutional privacy practices to support FERPA-compliant use of FCGI educational Services by schools and educational institutions subject to FERPA.

FCGI does not represent that a school's or educational institution's use of the Service automatically satisfies FERPA. Compliance also depends upon the educational agency or institution satisfying its own applicable obligations, including its determinations concerning authorized disclosures, direct control, legitimate educational interests, access controls, required notices, authorizations, and use of education records.

FCGI recognizes that schools and educational institutions subject to the Family Educational Rights and Privacy Act ("FERPA"), 20 U.S.C. § 1232g, and its implementing regulations, 34 C.F.R. Part 99, may use FCGI products and services in connection with education records or information maintained for educational purposes.

FERPA applies directly to educational agencies and institutions subject to FERPA. Where FCGI receives or maintains personally identifiable information from education records on behalf of a FERPA-covered school or educational institution, FCGI will process such information in accordance with the requirements applicable to FCGI's role and the applicable authorization, agreement, or FERPA exception relied upon by the educational institution.

14.11 FCGI AS AN OUTSOURCED SCHOOL OFFICIAL

Where a school or educational institution relies upon FERPA's school-official exception to provide FCGI with personally identifiable information from education records without obtaining separate consent, FCGI will act only within the scope permitted by FERPA and the applicable school or institutional authorization.

To the extent required for the school-official exception, FCGI will:

perform the institutional service or function for which the school or educational institution has engaged FCGI;

remain under the direct control of the school or educational institution with respect to FCGI's use and maintenance of personally identifiable information from education records;

use personally identifiable information from education records only for the purposes for which the information was disclosed;

restrict access to persons having a legitimate need to perform the applicable authorized service or function;

not redisclose personally identifiable information from education records except as permitted by FERPA, authorized by the applicable school or institution, authorized by the parent or eligible student where required, or otherwise permitted or required by applicable law; and

comply with applicable FERPA requirements governing the use and redisclosure of personally identifiable information from education records.

14.12 SCHOOL CONTROL AND LEGITIMATE EDUCATIONAL INTEREST

The applicable school or educational institution determines which of its authorized teachers, administrators, personnel, or other authorized users may access student information through FCGI's school or institutional services.

FCGI's systems may permit schools and institutions to administer student identifiers, gameplay assignments, practice activities, scores, progress information, competitions, assessments, educational reporting, or other authorized educational functionality.

FCGI does not authorize access to education records merely because a person claims to be a teacher, school employee, sponsor, promoter, partner, or other affiliated person.

Schools and institutions are responsible for identifying their authorized users and determining whether those users have the legitimate educational interest required by applicable law and institutional policy.

FCGI may implement technical, authentication, account, permission, and security controls designed to limit access to authorized users.

14.13 DATA MINIMIZATION UNDER FERPA

FCGI does not require a school or educational institution to provide more student-identifying information than reasonably necessary to provide the applicable Service.

Where a pseudonym, abbreviated name, initials, screen name, player identifier, or similar identifier is sufficient, FCGI encourages the school or institution to use that less-identifying alternative.

FCGI does not require students participating through an authorized educational program to provide personal email addresses or independently create ordinary FCGI consumer accounts merely to participate in the applicable educational activity.

14.14 USE OF FERPA-PROTECTED INFORMATION

FCGI will not use personally identifiable information obtained from education records under the FERPA school-official exception for purposes unrelated to the institutional service or function for which the information was disclosed.

FCGI will not use such information for unrelated behavioral advertising, cross-context behavioral advertising, unrelated commercial profiling, or sale.

FCGI will not provide such information to sponsors, promoters, advertisers, or other third parties merely because those parties sponsor, promote, fund, or otherwise participate in an FCGI educational program, GameKit, PlayKit, CompetitionKit, RewardsKit, promotion, reward, competition, or complimentary benefit.

14.15 SERVICE PROVIDERS AND FERPA INFORMATION

Where FCGI uses a service provider to support an educational Service involving personally identifiable information from education records, FCGI will limit the provider's access to information reasonably necessary to perform the authorized service.

FCGI will not authorize such a provider to use FERPA-protected information for its own unrelated advertising, marketing, profiling, sale, or other unrelated commercial purposes.

FCGI will use reasonable contractual, technical, administrative, or organizational safeguards appropriate to FCGI's role and the information involved.

14.16 ACCESS, CORRECTION, AND SCHOOL ADMINISTRATION

FCGI will reasonably cooperate with a school or educational institution where necessary to permit the institution to satisfy applicable FERPA obligations concerning education records maintained through FCGI's Service.

Where appropriate, requests concerning a student's education records should ordinarily be directed through the applicable school or educational institution because the school or institution controls the education record and determines the student's rights under FERPA.

Nothing in this provision prevents a parent, guardian, eligible student, school, or other legally authorized person from contacting FCGI as provided elsewhere in this Privacy Policy.

14.17 RETENTION, RETURN, DELETION, AND DESTRUCTION OF FERPA INFORMATION

FCGI will retain personally identifiable information from education records only for the period permitted by FERPA, other applicable law, the purpose for which the information was disclosed, the lawful instructions and direct control of the applicable educational agency or institution where required, and any binding School / Institutional Data Protection and FERPA Addendum or other applicable agreement.

Where FERPA, another applicable law, or a binding agreement requires FCGI to return, delete, or destroy personally identifiable information from education records, FCGI will take reasonable measures to return, delete, destroy, or otherwise cease maintaining that personally identifiable information within the applicable period.

FCGI's general rights to preserve gameplay history, scores, achievements, leaderboards, competition records, educational reporting, statistical information, security information, or other historical records do not override an applicable legal or contractual requirement to delete or destroy personally identifiable information from education records.

Where legally permitted, FCGI may preserve the underlying historical, statistical, gameplay, scoring, achievement, educational, competition, security, or analytical information after removing or transforming the information so that the retained information is no longer personally identifiable under applicable law.

Nothing in this Section requires FCGI to destroy information that has been lawfully aggregated or de-identified so that it is no longer personally identifiable, unless applicable law or a binding written agreement expressly requires otherwise.

Where a particular FERPA exception imposes specific retention, destruction, written-agreement, or other requirements, the requirements applicable to that particular disclosure control.

14.18 DE-IDENTIFIED AND AGGREGATED EDUCATIONAL INFORMATION

Subject to FERPA and other applicable law, FCGI may use information that has been aggregated or de-identified so that individual students are not personally identifiable for purposes including:

improving Full Color® Solitaire;
improving educational functionality;
evaluating game and educational performance;
developing educational tools;
statistical analysis;
benchmarking;
research;
product development;
curriculum-support analysis;
evaluating instructional methods; and
improving GameKit, PlayKit, CompetitionKit, RewardsKit, and other FCGI educational products.

For example, FCGI may analyze appropriately aggregated or de-identified information concerning average gameplay scores, performance improvements, grade-level performance, instructional outcomes, or use of particular educational methods where individual students are not personally identifiable.

14.19 NO OWNERSHIP OF SCHOOL EDUCATION RECORDS

FCGI does not acquire ownership of a school's education records merely because FCGI provides technology used by the school to create, process, maintain, display, analyze, or store those records.

As between FCGI and the applicable school or educational institution, the school or institution retains its rights in education records and educational information that it provides to or creates through the Service, subject to FCGI's ownership of its software, systems, intellectual property, aggregated or lawfully de-identified information, and other rights established by the applicable Terms or written agreement.

14.20 SCHOOL AGREEMENTS AND FERPA ADDENDA

FCGI may enter into a school, district, institutional, data-protection, student-privacy, or FERPA agreement or addendum governing a particular educational relationship.

Where such an agreement imposes additional legally binding privacy protections concerning education records, FCGI will comply with those protections according to the terms of the applicable agreement.

Nothing in this Privacy Policy authorizes a school, institution, teacher, administrator, sponsor, promoter, partner, or other person to provide FCGI with student information that the person is not legally authorized to disclose.

14.21 SCHOOL AND INSTITUTIONAL PRIVACY AGREEMENTS

FCGI may make available a separate School & Student Privacy Notice and a School / Institutional Data Protection and FERPA Addendum applicable to qualifying educational use of the Service.

A school, school district, educational institution, or other qualifying educational organization may be required to accept or execute an applicable educational, student-privacy, data-protection, FERPA, security, or other institutional agreement as a condition of accessing particular FCGI educational Services.

Where FCGI and a school or educational institution enter into a separate written agreement governing Personal Data or education records, that agreement supplements this Privacy Policy.

If a provision of an executed school or institutional agreement imposes a more specific or more protective requirement concerning education records or student Personal Data than this Privacy Policy, the applicable written agreement controls with respect to that institution and that information to the extent stated in the agreement and required by applicable law.

Nothing in this Privacy Policy authorizes a school, teacher, administrator, sponsor, promoter, partner, or other person to provide FCGI with Personal Data or education records that the person is not legally authorized to disclose.

14.22 CHILDREN'S ONLINE PRIVACY PROTECTION ACT ("COPPA")

FCGI has designed its children's and school privacy practices to support compliance with the Children's Online Privacy Protection Act ("COPPA"), 15 U.S.C. §§ 6501-6506, and the Children's Online Privacy Protection Rule, 16 C.F.R. Part 312, where COPPA applies to FCGI's collection, use, or disclosure of Personal Data concerning a child under 13 years of age.

FCGI does not rely upon a child's acceptance of FCGI's Terms or Privacy Policy as a substitute for verifiable parental consent, school authorization, or another form of authorization required by COPPA.

Where COPPA requires verifiable parental consent before FCGI collects, uses, or discloses Personal Data concerning a child, FCGI will obtain the required consent before engaging in the applicable processing unless an exception under COPPA permits the processing without prior parental consent.

14.23 SCHOOL AUTHORIZATION UNDER COPPA

Where permitted by COPPA, an educational institution may authorize FCGI's collection and processing of Personal Data concerning students on behalf of parents when FCGI collects and processes the information for the use and benefit of the school and for the authorized educational purpose.

FCGI will not rely upon school authorization to use children's Personal Data for an unrelated commercial purpose.

Where FCGI relies upon school authorization under COPPA, FCGI will provide the applicable school or educational institution with notice concerning the categories of Personal Data FCGI collects from participating children, the purposes for which the information is used, the circumstances in which it is disclosed, FCGI's retention practices, and the rights available concerning that information.

FCGI will use reasonable procedures designed to establish that the person or organization providing school authorization has authority to provide that authorization.

FCGI does not place responsibility for FCGI's own compliance with COPPA upon a school, teacher, parent, guardian, or other user.

14.24 MINIMUM INFORMATION NECESSARY

FCGI will not condition a child's participation in an activity upon disclosure of more Personal Data than is reasonably necessary for the child to participate in that activity.

Children participating through authorized educational programs are not required by FCGI to provide personal email addresses or independently establish ordinary FCGI consumer accounts merely to participate in the applicable educational activity.

FCGI encourages schools and institutions to use pseudonyms, initials, abbreviated names, screen names, player identifiers, or other minimally identifying identifiers where those identifiers are sufficient for the educational purpose.

14.25 PARENTAL AND SCHOOL RIGHTS UNDER COPPA

Where applicable under COPPA, FCGI will provide a parent, legal guardian, or school acting within the scope permitted by COPPA with the ability to:

obtain information concerning the categories of Personal Data collected from the child;
review Personal Data concerning the child maintained by FCGI;
request deletion of Personal Data concerning the child;
refuse to permit further collection or use of the child's Personal Data; and
exercise other rights required by COPPA.

Requests may be submitted in writing to:

privacy@fullcolorgames.com

FCGI may use reasonable procedures to verify the identity and authority of the person or institution making the request before providing access to, modifying, or deleting information concerning a child.

14.26 CHILDREN'S DATA AND THIRD PARTIES

FCGI does not sell children's Personal Data.

FCGI does not disclose children's Personal Data to third parties for targeted advertising or unrelated commercial profiling.

FCGI does not use school authorization as authorization to disclose children's Personal Data for unrelated commercial purposes.

Where a service provider processes children's Personal Data on FCGI's behalf, FCGI will take reasonable steps required by applicable law to determine that the provider is capable of maintaining the confidentiality, security, and integrity of the information and will obtain contractual or other assurances where required by applicable law.

Where COPPA requires separate verifiable parental consent for a disclosure of children's Personal Data to a third party, FCGI will obtain the applicable consent before making the disclosure unless an applicable COPPA exception permits the disclosure.

14.27 PERSISTENT IDENTIFIERS AND INTERNAL OPERATIONS

FCGI may process limited persistent identifiers or comparable technical information where permitted by COPPA for purposes supporting the internal operations of the Service.

Such purposes may include:

maintaining or analyzing Service functionality;
network communications;
authentication;
security;
fraud prevention;
game integrity;
protection against cheating or manipulation;
debugging;
application performance;
statistical reporting;
optimization;
legal or regulatory compliance; and
other internal operational purposes permitted by COPPA.

FCGI will not rely upon an internal-operations exception to use a child's persistent identifier for behavioral advertising, unrelated commercial profiling, contacting the child, or another purpose outside the applicable COPPA exception.

14.28 CHILDREN'S PERSONAL DATA RETENTION AND DELETION

FCGI will maintain a written retention and deletion policy governing Personal Data collected from children where required by COPPA.

FCGI will retain children's Personal Data only for as long as reasonably necessary to fulfill the specific purpose for which the information was collected or as otherwise permitted or required by applicable law.

FCGI will not retain children's Personal Data indefinitely merely because continued storage is technically possible or potentially useful.

When children's Personal Data is no longer reasonably necessary for the applicable purpose and no other lawful retention requirement applies, FCGI will delete the information using reasonable measures designed to protect against unauthorized access or use in connection with its disposal.

FCGI may retain appropriately aggregated or de-identified information where the information no longer constitutes Personal Data concerning an identifiable child under applicable law.

Nothing in FCGI's general game-history, scoring, leaderboard, achievement, competition, or educational-record retention provisions overrides an applicable COPPA requirement concerning retention or deletion of children's Personal Data.

14.29 SECURITY OF CHILDREN'S PERSONAL DATA

FCGI will establish and maintain reasonable procedures designed to protect the confidentiality, security, and integrity of children's Personal Data.

FCGI will maintain a written information-security program where required by COPPA.

FCGI will take reasonable steps required by applicable law before permitting a service provider or other authorized third party to process children's Personal Data, including obtaining appropriate assurances concerning the provider's ability to maintain the confidentiality, security, and integrity of the information.

14.30 NO TARGETED ADVERTISING BASED ON SCHOOL CHILD DATA

FCGI does not use children's Personal Data obtained through school-authorized educational use for targeted advertising, behavioral advertising, cross-context behavioral advertising, unrelated commercial profiling, or sale.

Sponsor branding, complimentary gameplay, promotional codes, educational sponsorships, GameKits, PlayKits, CompetitionKits, RewardsKits, or other sponsored benefits do not authorize FCGI or the sponsor to use children's school-authorized Personal Data for unrelated advertising purposes.

A sponsor's funding of an educational or promotional benefit does not itself entitle that sponsor to receive Personal Data identifying the participating child.

14.31 INTERACTION WITH FERPA AND OTHER CHILDREN'S PRIVACY LAWS

COPPA may apply together with FERPA, state student-privacy laws, state consumer-privacy laws, contractual school requirements, or other applicable protections.

FCGI will apply the requirements applicable to the particular information and processing activity.

Where another applicable law or binding school agreement provides greater protection that cannot lawfully be waived, the applicable greater protection will control to the extent required by law.

15. USER-GENERATED CONTENT, PROFILES, SHARING, AND PUBLIC FEATURES

Certain FCGI functionality may permit users to create, submit, display, transmit, publish, or share content.

Depending upon the available functionality, this may include:

screen names;
profile information;
gameplay information;
scores;
achievements;
leaderboard information;
photographs or images;
screenshots;
comments;
messages;
public posts; or
other user-submitted content.

Users should understand that information they affirmatively choose to make public may be visible to other users and may be copied, redistributed, indexed, captured, or otherwise used by persons outside FCGI's control.

Users should not publicly disclose Personal Data or sensitive information that they do not want others to see.

15.1 LEADERBOARDS AND ACHIEVEMENTS

Public leaderboards and achievement displays ordinarily use a screen name, player name, pseudonym, or similar identifier together with the applicable score, ranking, achievement, or gameplay information.

FCGI does not require a user's real-world identity to be publicly displayed on a leaderboard where a screen name or pseudonym is sufficient.

A user's real-world identity may be displayed where the user affirmatively chooses or authorizes such identification or where another supported platform feature operates according to the user's settings and applicable platform rules.

15.2 SOCIAL SHARING

FCGI may provide functionality that allows a user to share screenshots, gameplay results, achievements, scores, images, or other content through Facebook, Apple-supported services, or other third-party platforms.

The user must elect to use the applicable sharing functionality.

Where a user chooses to share content through a third-party platform, the user's interaction with that platform is also governed by the third party's applicable terms, privacy practices, account settings, and permissions.

FCGI does not control information after a user independently publishes or shares that information through a third-party service.

Users are responsible for reviewing content before electing to make it public or transmit it to another service.

15.3 INTELLECTUAL PROPERTY IN SHARED CONTENT

The ability to view, access, display, capture, or share content through the Service does not transfer ownership of FCGI's or any third party's intellectual property.

Certain artwork, game elements, designs, images, photographs, audiovisual material, trademarks, copyrights, or other content appearing through the Service may be owned by David W. Mahon, FCGI, licensors, sponsors, or other rights holders and may be used by FCGI under license, permission, or other authorization.

Nothing in this Privacy Policy grants a license to reproduce, commercially exploit, redistribute, broadcast, sublicense, sell, or otherwise use protected content except to the extent expressly permitted by the applicable Service, license, Terms, or rights holder.

Questions concerning licensing, permissions, or authorized uses may be directed to:

licensing@fullcolorgames.com

Additional intellectual-property, licensing, acceptable-use, and user-content requirements may be contained in FCGI's applicable Terms and Conditions or other agreements.

16. THIRD-PARTY SERVICES, SOFTWARE DEVELOPMENT KITS, AND SERVICE PROVIDERS

FCGI uses third-party technology and service providers to perform specific functions necessary or useful to provide, maintain, secure, support, communicate through, analyze, and improve the Service.

These providers may include cloud infrastructure providers, analytics providers, diagnostic and performance services, push-notification services, customer-support providers, platform providers, authentication providers, content-delivery providers, and other technical service providers.

FCGI currently uses or may use services associated with:

Amazon Web Services ("AWS");
Google Analytics;
Google Firebase;
Meta/Facebook;
OneSignal;
Zendesk;
Apple, including Apple App Store, In-App Purchase, Sign in with Apple, Apple Push Notification Service, and Game Center; and
other infrastructure, content-delivery, security, verification, or technical providers that may become reasonably necessary as the Service develops.

The fact that FCGI uses a third-party service does not mean that FCGI provides that service with all information maintained by FCGI.

16.1 SEPARATION OF FCGI ACCOUNT INFORMATION FROM THIRD-PARTY SDKs

FCGI does not provide user-supplied FCGI registration or profile information to third-party SDK providers merely because their technology is incorporated into the Service.

For example, if a user provides FCGI with a name and email address when creating an FCGI account, FCGI does not transmit that name and email address to an analytics or diagnostic SDK merely because the SDK operates within the application.

FCGI does not authorize third-party SDK providers to obtain FCGI account-registration information for the provider's unrelated advertising, marketing, sale, profiling, or other unrelated commercial purposes.

A third-party SDK or technical service may nevertheless independently generate, receive, or process limited technical information necessary for the function it performs.

Depending upon the provider and functionality, this may include:

IP address;
device model or class;
operating-system information;
application version;
installation identifier;
session information;
diagnostic information;
crash information;
performance information;
technical analytics events;
network information; or
other technical information reasonably associated with providing the applicable service.

The information processed by a provider depends upon the technology actually used, its configuration, the user's device and permissions, applicable platform requirements, and applicable law.

16.2 GOOGLE ANALYTICS AND FIREBASE

FCGI may use Google Analytics and limited Firebase functionality for analytics, Crashlytics, and performance monitoring.

FCGI uses these services to understand application operation, identify device and technical characteristics, diagnose crashes and performance problems, maintain security, investigate abnormal activity, and improve the reliability and performance of the Service.

FCGI does not currently use Firebase as the required registration system for FCGI consumer accounts.

FCGI does not provide user-supplied FCGI names or registration email addresses to Google or Firebase merely because these analytics, crash, or performance services are incorporated into the Service.

16.3 META/FACEBOOK

FCGI may permit a user to use supported Meta/Facebook functionality voluntarily.

This may include using a Facebook account as an available registration or login method or electing to share supported content, such as a screenshot, gameplay result, score, achievement, or similar content, to the user's own Facebook account.

Use of Facebook functionality requires the user's interaction with or authorization of the applicable Facebook service.

FCGI does not require a user to maintain a Facebook account merely to play the basic game.

FCGI does not provide Personal Data independently supplied by a user to FCGI, such as the user's FCGI registration name, registration email address, or FCGI profile information, to Meta merely because Meta/Facebook functionality or an SDK is incorporated into the Service.

Where a user affirmatively elects to use Facebook Login, sharing functionality, or another supported Meta/Facebook feature, information necessary to perform the user-requested functionality may be exchanged with Meta in accordance with the user's request, applicable permissions, FCGI's configuration of the applicable functionality, applicable law, and Meta's platform requirements.

Meta/Facebook may independently process information when a user uses Meta services according to Meta's own terms, privacy practices, permissions, and platform functionality.

A user who uses Facebook to create or access an FCGI Account may request deletion of the user's FCGI Account and Personal Data as provided in Sections 25 and 35 of this Privacy Policy.

Deletion of an FCGI Account does not itself delete the user's independent Facebook account or information independently maintained by Meta under Meta's own legal authority.

Where applicable Meta platform requirements require FCGI to revoke, delete, disassociate, or otherwise terminate FCGI's access to applicable Facebook authentication credentials, tokens, permissions, or data in connection with deletion of the user's FCGI Account, FCGI will perform the applicable action as required.

16.4 ONESIGNAL

FCGI may use OneSignal to provide push-notification, analytics, and segmentation functionality.

FCGI may use such functionality to:

deliver game and Service notifications;
administer account-dependent communications;
organize or segment authorized users for applicable Service functions;
support schools, educators, and institutions;
initiate scheduled educational, practice, training, competition, or scoring activities;
notify participants of a designated game, seed, assignment, or event;
administer promotions or promotional codes;
provide sponsor-funded or complimentary gameplay;
provide competitions or rewards; and
perform analytics reasonably related to these functions.

For school and institutional use, OneSignal-supported functionality may be used to facilitate activities configured or authorized by the applicable school, educator, institution, or administrator.

FCGI does not authorize OneSignal to sell FCGI-provided student information or use FCGI-provided student information for unrelated commercial profiling.

16.5 AMAZON WEB SERVICES AND CLOUD INFRASTRUCTURE

FCGI currently uses AWS as a cloud infrastructure provider.

Information maintained through FCGI's backend systems may be stored or processed using AWS infrastructure in the United States.

Depending upon the Service functionality, AWS infrastructure may support:

account information;
authentication;
game-state information;
gameplay history;
scores and achievements;
account restoration;
security records;
fraud-prevention records;
application data;
educational functionality;
competition functionality;
analytics maintained by FCGI;
user-requested historical information; and
other backend functions.

AWS acts as infrastructure supporting FCGI's operation of the Service. FCGI's use of AWS does not authorize AWS to sell FCGI user account information or use it for unrelated advertising or commercial profiling.

As FCGI expands, FCGI may use additional cloud, content-delivery-network, caching, verification, security, or infrastructure providers to improve availability, latency, performance, security, and delivery of Service data.

Where additional providers process Personal Data, FCGI will use them consistently with applicable law and this Privacy Policy.

16.6 ZENDESK AND CUSTOMER SUPPORT

FCGI uses Zendesk for customer service, technical support, support-ticket management, troubleshooting, and related communications.

When a user requests customer support, FCGI and Zendesk may process information that the user voluntarily provides in connection with the support request.

Depending upon what the user chooses to provide, this may include:

name;
email address;
screen name;
account or player identifier;
correspondence;
screenshots;
attachments;
device information;
application information;
transaction information;
diagnostic information;
gameplay information; or
other information relevant to the support request.

Users are not required to provide information that is unnecessary to resolve their support request.

Information submitted through FCGI's customer-support system may be transmitted to and processed by Zendesk for purposes of receiving, routing, maintaining, securing, responding to, and resolving the applicable support request.

FCGI does not authorize Zendesk to sell information submitted through an FCGI support request or use that information for unrelated advertising or commercial profiling.

Users should not submit sensitive Personal Data through customer support unless reasonably necessary to resolve the applicable matter.

16.7 APPLE SERVICES

FCGI currently distributes Full Color® Solitaire through the Apple App Store.

FCGI may use Apple services including:

Apple App Store;
Apple In-App Purchase;
Sign in with Apple;
Apple Push Notification Service;
Game Center;
Apple multiplayer functionality; and
other Apple technologies necessary or useful to provide supported features.

Apple's processing of information through Apple services is governed by Apple's applicable terms, privacy policies, settings, and platform requirements in addition to FCGI's obligations concerning information FCGI itself processes.

17. APPLE IN-APP PURCHASES, PURCHASES, AND SUBSCRIPTIONS

Purchases currently offered through the iOS version of the Service are processed through Apple's In-App Purchase system.

FCGI does not directly receive or store a user's complete credit-card or debit-card number merely because the user makes an Apple In-App Purchase.

Apple processes the payment transaction under Apple's applicable terms and privacy practices.

FCGI may receive or maintain information concerning the transaction that is reasonably necessary to provide, verify, restore, administer, account for, secure, or support the purchased product or subscription.

This may include:

purchase history;
product or subscription purchased;
subscription status;
transaction or receipt identifiers;
entitlement information;
renewal or expiration information;
restoration information;
refund or revocation information; or
other transaction metadata made available through the applicable platform.

FCGI may retain transaction-related information where reasonably necessary for accounting, tax, fraud prevention, security, customer support, entitlement verification, chargeback or refund administration, legal compliance, dispute resolution, or other legitimate business purposes.

18. COOKIES, WEBSITE TECHNOLOGIES, AND WEB SESSION INFORMATION

FCGI websites, including Full Color® Solitaire web properties, may use cookies, session technologies, local storage, log files, or similar technologies reasonably necessary to provide, secure, authenticate, analyze, and maintain website functionality.

FCGI may use these technologies to:

maintain a website session;
authenticate a registered user's web session;
permit a user to access account-dependent gameplay history or analytics;
protect accounts;
detect fraud, abuse, or unauthorized access;
remember appropriate settings;
provide requested website functionality;
understand website performance;
diagnose errors;
administer subscriber communications;
support promotional-code redemption;
support notification-related functionality; and
maintain website security.

FCGI's website is primarily informational and may also provide access to account-dependent functionality, news, subscriber services, promotional redemption, or expanded gameplay information.

FCGI may collect an email address where a user voluntarily subscribes to news or another email-based service.

FCGI does not require acceptance of unrelated advertising cookies merely to provide website functionality that can reasonably operate without them.

Where applicable law requires consent before a particular non-essential cookie or similar technology may be used, FCGI will request the applicable consent.

19. ANALYTICS, SECURITY, FRAUD PREVENTION, AND GAME INTEGRITY

FCGI collects and processes technical, diagnostic, usage, session, device, network, and gameplay information where reasonably necessary to operate, secure, analyze, maintain, and improve the Service.

These activities are particularly important to preserve the authenticity and integrity of gameplay, scores, achievements, competitions, educational activities, rewards, and leaderboards.

FCGI may use information to:

authenticate legitimate gameplay and game sessions;
validate scores;
validate achievements;
validate rankings and leaderboards;
validate game results;
detect cheating or manipulation;
detect automated or unauthorized activity;
detect unauthorized modification of the application or game state;
detect exploitation of vulnerabilities;
detect circumvention of game rules;
identify suspicious account, device, session, or gameplay behavior;
prevent duplicate or fraudulent promotional redemption;
detect injection attacks or attempted database manipulation;
detect unauthorized access;
investigate attacks against FCGI systems;
prevent fraud and abuse;
protect other users;
maintain application and network security;
diagnose crashes, errors, and technical failures;
analyze performance;
maintain availability and reliability;
investigate disputes concerning gameplay or results;
enforce competition and promotion rules; and
enforce FCGI's Terms and other applicable agreements.

FCGI may compare technical, device, location, account, session, gameplay, transaction, or other relevant information where reasonably necessary to identify inconsistencies associated with fraud, cheating, manipulation, unauthorized access, or abuse.

19.1 SECURITY PROCESSING IS NOT NECESSARILY ADVERTISING TRACKING

FCGI's use of technical information to recognize a session, authenticate gameplay, identify a device, detect fraud, investigate abuse, protect an account, validate a score, or preserve game integrity is undertaken for operational and security purposes.

FCGI does not characterize such processing as advertising merely because information is used to follow the progression of a game session, recognize suspicious activity, or associate activity with an account or device.

Where a platform or applicable law separately defines "tracking," "targeted advertising," "cross-context behavioral advertising," or a similar term, FCGI applies the applicable legal or platform definition to determine whether the processing falls within that category.

20. IDFA AND APP TRACKING TRANSPARENCY

FCGI does not currently access or use Apple's Identifier for Advertisers ("IDFA").

FCGI does not currently use IDFA for advertising, security, authentication, analytics, attribution, or other purposes.

FCGI does not currently use App Tracking Transparency ("ATT") authorization to obtain access to IDFA.

FCGI uses other technical, account, device, session, gameplay, and security mechanisms to authenticate activity, detect fraud and abuse, protect accounts, preserve game integrity, and validate gameplay, scores, leaderboards, and achievements.

If FCGI materially changes these practices in the future, FCGI will implement any notice, permission, consent, ATT authorization, App Store disclosure, or other requirement applicable to the new processing before using the applicable functionality where required.

21. HOW FCGI DISCLOSES PERSONAL DATA

FCGI does not sell Personal Data under its current business practices.

FCGI may disclose Personal Data only as reasonably necessary for purposes described in this Privacy Policy, at the user's direction, with applicable authorization, or as otherwise permitted or required by law.

21.1 SERVICE PROVIDERS

FCGI may disclose or make Personal Data available to service providers that perform functions on FCGI's behalf or provide infrastructure used to operate the Service.

Such functions may include:

cloud hosting;
data storage;
security;
analytics;
diagnostics;
performance monitoring;
push notifications;
customer support;
authentication;
content delivery;
transaction support;
fraud prevention;
communications; and
other technical or operational services.

FCGI seeks to limit service-provider processing to the applicable service and does not authorize a service provider acting on FCGI's behalf to sell FCGI-provided Personal Data or use it for unrelated advertising or commercial profiling except where separately disclosed and lawfully authorized.

21.2 AT THE USER'S DIRECTION

FCGI may disclose information when a user affirmatively directs FCGI to do so.

Examples may include:

social sharing;
public profile choices;
leaderboard identity choices;
multiplayer connections;
customer-support requests;
competitions;
rewards;
promotions; or
another feature through which the user affirmatively elects to transmit or publish information.

21.3 SCHOOLS AND INSTITUTIONS

Where a user participates through a school, educational institution, or other authorized institutional program, FCGI may make information available to the authorized school, institution, teacher, administrator, or other authorized person as reasonably necessary to provide the applicable program.

This may include gameplay results, scores, achievements, assignments, progress information, competition information, educational reporting, or other information associated with the authorized program.

FCGI does not authorize an educational institution's access to one student's information to be used as authority to access unrelated information belonging to other users.

21.4 SPONSORS, PROMOTERS, AND PARTNERS

FCGI may work with sponsors, promoters, partners, or other organizations in connection with promotions, complimentary gameplay, subscriptions, competitions, rewards, educational programs, or other benefits.

Sponsorship or participation in such a program does not itself entitle the sponsor, promoter, or partner to receive FCGI account information.

Where FCGI intends to disclose identifying Personal Data to a sponsor, promoter, partner, prize provider, fulfillment provider, or other third party as part of a particular program, FCGI will provide any additional notice, choice, consent, or authorization required by applicable law.

21.5 LEGAL PROCESS, SAFETY, SECURITY, AND ENFORCEMENT

FCGI may preserve, access, use, or disclose information where FCGI reasonably believes doing so is necessary or appropriate to:

comply with applicable law;
respond to lawful legal process;
comply with a court order, warrant, subpoena, regulatory request, or other legally valid demand;
establish, exercise, or defend legal claims;
preserve evidence;
comply with litigation, anticipated-litigation, regulatory, or investigative holds;
investigate fraud, cheating, abuse, unauthorized access, or security incidents;
protect the rights, property, security, or safety of FCGI;
protect users or other persons;
prevent or investigate unlawful activity;
enforce FCGI's Terms, competition rules, promotion rules, licenses, or other agreements;
resolve disputes;
investigate chargebacks, refunds, or payment disputes; or
protect the integrity of FCGI's games, scoring systems, leaderboards, achievements, competitions, rewards, networks, data, or services.

Requests, demands, orders or other legal process from courts, law-enforcement agencies, regulatory authorities, governmental agencies or other public authorities are additionally subject to Section 21.6.

21.6 PUBLIC-AUTHORITY AND GOVERNMENT REQUESTS

FCGI may receive requests, demands, subpoenas, warrants, orders or other legal process from courts, law-enforcement agencies, regulatory authorities, governmental agencies or other public authorities seeking Personal Data or other information.

Receipt of a request, demand, subpoena, warrant, order or other legal process does not, by itself, constitute FCGI's agreement or determination that the request is lawful, valid, enforceable, properly issued, within the requesting authority's jurisdiction or entitled to the full scope of information requested.

FCGI will review such requests according to applicable law and FCGI's applicable legal, privacy, security and information-governance procedures before disclosing information, except where applicable law permits or requires a different procedure.

FCGI may require a requesting authority to provide legally sufficient process, authority, jurisdiction, scope or other information reasonably necessary to evaluate the request.

To the extent permitted by applicable law, FCGI may reject, object to, seek clarification or narrowing of, challenge, move to quash, seek protective relief concerning or otherwise contest a request that FCGI determines is unlawful, invalid, defective, overbroad, disproportionate, beyond the requesting authority's jurisdiction or otherwise legally objectionable.

Where FCGI determines that disclosure is legally required or otherwise lawfully appropriate, FCGI will seek to limit the disclosure to information reasonably necessary to satisfy the applicable lawful request and will not intentionally disclose additional Personal Data merely because additional information is available to FCGI.

Subject to applicable law, privilege, confidentiality obligations, security requirements and lawful restrictions upon disclosure, FCGI may maintain records concerning public-authority requests and FCGI's handling of those requests, including:

(a) the requesting authority;
(b) the date and nature of the request;
(c) the legal authority or process asserted;
(d) the information requested;
(e) the persons or functions involved in reviewing or responding to the request;
(f) FCGI's evaluation of the request;
(g) objections, challenges, requests for clarification or efforts to narrow the request;
(h) the response provided by FCGI;
(i) the information, if any, disclosed;
(j) the legal basis for disclosure, nondisclosure or other response; and
(k) other information reasonably necessary to document FCGI's compliance, protect legal rights, preserve evidence or demonstrate accountability.

FCGI may preserve such records for legal, regulatory, compliance, security, evidentiary, dispute-resolution and other lawful purposes.

Nothing in this Section requires FCGI to disclose privileged legal advice, attorney work product, confidential legal analysis, security-sensitive information or other information protected from disclosure by applicable law.

21.7 BUSINESS TRANSACTIONS

If FCGI participates in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of assets, corporate restructuring, due diligence process, or similar business transaction, information may be disclosed to or transferred as part of that transaction where permitted by applicable law.

Any successor receiving Personal Data will remain subject to applicable privacy obligations concerning that information.

Where applicable law requires additional notice, consent, or another procedure because of a material change in how Personal Data will be used, FCGI or the applicable successor will provide the required procedure.

22. NO SALE OF PERSONAL DATA

FCGI does not sell any Personal Data.

FCGI does not sell any children's Personal Data.

FCGI does not sell any students' Personal Data.

FCGI does not treat a sponsor's funding of a promotion, advertisement, competition, reward, complimentary subscription, complimentary gameplay, educational program, or other benefit as a sale of the recipient's Personal Data merely because the sponsor funded the benefit.

FCGI does not provide a sponsor with a user's FCGI registration name, registration email address, account credentials, or other directly identifying FCGI account information merely because the user receives a sponsor-funded benefit.

If FCGI materially changes its practices concerning the sale or other legally regulated disclosure of Personal Data in the future, FCGI will update its practices, notices, choices, consent mechanisms, platform disclosures, and this Privacy Policy as required by applicable law before applying the changed practice to Personal Data where required.

23. ADVERTISING, SPONSORED CONTENT, AND TRACKING

FCGI does not currently operate a conventional third-party advertising network within Full Color® Solitaire.

FCGI does not currently display conventional third-party banner advertisements or interstitial advertising-network advertisements as part of ordinary gameplay.

FCGI may display sponsor branding, promotional content, or other sponsored material in connection with a promotion, complimentary benefit, competition, reward, educational program, or other sponsored experience.

For example, where a user voluntarily redeems a sponsor-funded promotional code or benefit, the user's game background may display the sponsor's FCGI-approved name, image, likeness, trademark, or other promotional material during the applicable sponsored experience.

FCGI may use information such as geographic eligibility, promotion eligibility, redemption history, account status, gameplay status, or other information reasonably necessary to determine whether a user is eligible for a particular FCGI or sponsor-funded promotion.

FCGI does not currently use IDFA.

FCGI does not currently use IDFA to track users across applications or websites owned by other companies.

FCGI does not currently provide FCGI user-supplied account information to third-party advertising networks for cross-context behavioral advertising.

Where applicable law or a platform defines "sale," "sharing," "targeted advertising," "cross-context behavioral advertising," "tracking," or a similar concept, FCGI applies the applicable definition rather than treating every internal use of account, session, gameplay, device, security, or analytics information as advertising tracking.

If FCGI introduces materially different advertising or tracking practices in the future, FCGI will implement any notice, consent, opt-out, platform authorization, or other mechanism required by applicable law or applicable platform requirements before using the applicable processing where required.

24. DATA RETENTION

The retention provisions of this Section are subject to the Children, Students, Schools, Parents, and Guardians provisions of this Privacy Policy, including Sections 14.10 through 14.31 concerning FERPA, COPPA, educational information, and children's Personal Data, applicable law, and any binding School / Institutional Data Protection and FERPA Addendum or other written agreement applicable to the information.

Nothing in this Section authorizes FCGI to retain Personal Data where FERPA, COPPA, another applicable law, a binding regulatory requirement, or a binding school or institutional agreement requires FCGI to return, delete, destroy, de-identify, or otherwise cease maintaining that Personal Data.

Subject to those requirements, FCGI retains Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy or as otherwise permitted or required by applicable law.

Retention periods may vary according to:

the category and sensitivity of the information;
the purpose for which the information was collected or processed;
the applicable Service or feature;
whether the user maintains a registered Account;
whether information is associated with Anonymous Play;
whether the information relates to a school, student, or educational program;
whether the information relates to a purchase, subscription, competition, reward, promotion, or sponsored benefit;
security, fraud-prevention, abuse-prevention, and game-integrity requirements;
accounting, tax, transaction, and recordkeeping requirements;
legal, regulatory, contractual, and evidentiary requirements; and
other lawful operational purposes described in this Privacy Policy.
FCGI may retain information where reasonably necessary to:
provide, maintain, secure, and support the Service;
maintain a registered Account;
authenticate users, devices, sessions, and gameplay;
restore an Account, purchase, subscription, entitlement, gameplay history, or other account-dependent information;
preserve game history;
preserve scoring systems;
maintain leaderboard integrity;
maintain achievements;
maintain competition and reward records;
preserve legitimate educational reporting;
maintain school-authorized records for the period permitted by applicable law and the applicable educational relationship;
prevent, detect, investigate, and respond to fraud;
prevent, detect, investigate, and respond to cheating, manipulation, abuse, or unauthorized access;
maintain security and game integrity;
investigate attacks, injection attempts, exploits, or other security incidents;
prevent duplicate, fraudulent, or unauthorized promotional redemption;
provide customer support;
maintain transaction, subscription, accounting, tax, refund, and chargeback records;
resolve disputes;
enforce FCGI's Terms, licenses, competition rules, promotion rules, and other agreements;
comply with applicable law, regulation, legal process, or governmental requirements;
establish, exercise, or defend legal claims;
preserve evidence;
comply with litigation, anticipated-litigation, regulatory, investigative, or other lawful preservation holds; and
protect FCGI, its users, schools, institutions, sponsors, partners, promoters, service providers, and other persons.

FCGI will not retain Personal Data indefinitely merely because continued storage is technically possible or because the information might conceivably become useful in the future where applicable law requires a defined purpose and appropriate retention period.

Where information no longer needs to remain associated with an identifiable individual, FCGI may delete, anonymize, aggregate, pseudonymize, dissociate, or otherwise de-identify the information where appropriate and permitted by applicable law.

FCGI may retain aggregated, anonymized, or lawfully de-identified information for longer periods where permitted by applicable law.

Such information may be retained for purposes including:

historical game records;
statistical analysis;
analytics;
research;
benchmarking;
security analysis;
fraud-prevention analysis;
game balancing;
product development;
performance analysis;
educational analysis;
curriculum and training improvement;
development and improvement of educational tools;
evaluation of gameplay and instructional methods; and
improvement of FCGI products, systems, technologies, and services.

24.1 HISTORICAL GAMEPLAY RECORDS

Game history may have consequences beyond the Account or individual that generated a particular record.

A completed game may affect:

scores;
achievements;
rankings;
leaderboards;
competitions;
rewards;
educational reporting;
statistical history;
game-integrity analysis;
fraud-prevention analysis;
security analysis;
other players' scores or rankings; or
other legitimate historical records.

Deletion of an Account therefore does not necessarily require deletion of the historical fact that a game occurred or alteration of otherwise legitimate historical results.

Subject to FERPA, COPPA, other applicable law, and any binding school or institutional agreement, FCGI may preserve historical gameplay records where reasonably necessary to maintain accurate game history, scoring systems, rankings, leaderboards, achievements, competitions, rewards, educational reporting, statistical information, fraud-prevention systems, security records, or other legitimate records.

Where FCGI is required to delete Personal Data identifying the person associated with a historical record, FCGI may preserve the underlying historical game, score, achievement, ranking, statistical, competition, educational, security, or other record only to the extent continued retention is permitted by applicable law.

Where reasonably practicable and appropriate, FCGI may delete, anonymize, de-identify, pseudonymize, or dissociate directly identifying Account information while preserving the underlying lawful historical record.

A retained historical record may continue to use a screen name, abbreviated name, pseudonym, historical player identifier, or similar identifier only where continued use of that identifier is permitted by applicable law.

24.2 SCHOOL, STUDENT, AND EDUCATIONAL RECORD RETENTION

School, student, and educational information is subject to the additional protections provided in Sections 14.10 through 14.31, applicable law, and any binding School / Institutional Data Protection and FERPA Addendum or other agreement between FCGI and the applicable school or educational institution.

FCGI may maintain gameplay scores, assignments, assessments, grades, progress information, training records, competition records, reporting information, and other educational information for the period reasonably necessary to provide the educational Service authorized by the applicable school or institution.

Where FCGI receives or maintains personally identifiable information from education records subject to FERPA, FCGI will retain, return, delete, destroy, de-identify, or otherwise handle that information in accordance with:

the FERPA requirements applicable to the particular disclosure;
the purpose for which the information was disclosed;
the lawful instructions and direct control of the applicable educational agency or institution where required;
other applicable federal, state, or local student-privacy law; and
any binding School / Institutional Data Protection and FERPA Addendum or other applicable written agreement.

Nothing in FCGI's interest in maintaining game history, scoring systems, leaderboards, achievements, educational reporting, statistical history, competition integrity, fraud-prevention records, or security records authorizes FCGI to retain personally identifiable information from education records after FCGI is legally or contractually required to return, delete, or destroy that personally identifiable information.

Where FCGI is required to delete or destroy personally identifiable student information, FCGI may preserve an underlying historical game, score, achievement, statistical, educational, competition, security, or analytical record only where continued retention of that record is permitted by applicable law, including where the record has been lawfully de-identified, aggregated, dissociated, or otherwise transformed so that the retained information is no longer personally identifiable.

Where permitted by FERPA, COPPA, and other applicable law, FCGI may retain and use properly aggregated or de-identified educational information for statistical analysis, historical game integrity, research, benchmarking, product development, educational analysis, curriculum-support analysis, evaluation of instructional methods, and improvement of FCGI products and services.

A school or educational institution may independently maintain education records according to its own lawful retention obligations and policies.

Deletion of information from FCGI's systems does not require FCGI to direct an educational institution to destroy records independently maintained by that institution unless applicable law or a binding agreement requires otherwise.

24.3 CHILDREN'S PERSONAL DATA RETENTION

Where COPPA applies, FCGI will retain Personal Data collected from a child only for as long as reasonably necessary to fulfill the specific purpose for which the information was collected or as otherwise permitted or required by applicable law.

FCGI will not retain children's Personal Data indefinitely merely because continued storage is technically possible or potentially useful.

When children's Personal Data is no longer reasonably necessary for the purpose for which it was collected and no other lawful retention basis applies, FCGI will delete the Personal Data using reasonable measures designed to protect against unauthorized access to or use of the information in connection with its disposal.

Nothing in FCGI's general game-history, scoring, leaderboard, achievement, competition, reward, educational-reporting, statistical, fraud-prevention, or security-record retention practices overrides an applicable COPPA requirement concerning retention or deletion of children's Personal Data.

Where permitted by applicable law, FCGI may preserve appropriately aggregated, anonymized, or de-identified information that no longer constitutes Personal Data concerning an identifiable child.

24.4 LEGAL, SECURITY, FRAUD, PUBLIC-AUTHORITY, AND EVIDENTIARY RETENTION

Subject to applicable law, FCGI may preserve information that otherwise might be eligible for deletion where reasonably necessary to:

comply with applicable law;
comply with valid and legally sufficient legal process;
review, evaluate, respond to, object to, challenge, narrow, document, or otherwise administer a request from a court, law-enforcement agency, regulatory authority, governmental agency, or other public authority;
document the legal authority, scope, review, persons involved, response, disclosure, objection, challenge, disposition, or legal basis associated with such a request;
preserve evidence;
comply with a litigation hold;
prepare for reasonably anticipated litigation;
respond to a regulatory, governmental, or law-enforcement investigation or request;
establish, exercise, protect, or defend legal rights or claims;
investigate fraud;
investigate cheating or Game manipulation;
investigate security incidents;
investigate unauthorized access;
investigate abuse;
enforce contractual or legal rights;
investigate Competitions, promotions, Rewards, eligibility disputes, payment disputes, refunds, or chargebacks;
prevent continuing or recurring abuse; or
protect FCGI, its Users, schools, institutions, licensors, service providers, or other persons.

Information preserved for one of these purposes may be segregated, access-restricted, removed from ordinary operational use, or otherwise protected where reasonably appropriate.

Retention of records concerning a public-authority request does not authorize disclosure of Personal Data beyond the scope permitted or required by applicable law.

This Section does not authorize retention where applicable law affirmatively requires deletion or destruction notwithstanding FCGI's asserted retention interest.

25. ACCOUNT AND PERSONAL DATA DELETION

A registered user may request deletion of the user's FCGI Account through the account-deletion functionality made available within the applicable FCGI application.

FCGI may also permit a user, parent, legal guardian, school, educational institution, or other legally authorized person to submit an applicable account-deletion or privacy request in writing to:

privacy@fullcolorgames.com

Where FCGI directs a user from the application to a web-based account-deletion process, FCGI will provide access to the applicable account-deletion process in accordance with applicable platform requirements.

FCGI may take reasonable measures to authenticate the requester, verify the requester's authority where applicable, protect against unauthorized or fraudulent deletion, and confirm that deletion is intentional before completing the deletion.

Subject to FERPA, COPPA, other applicable law, applicable platform requirements, and any binding school, institutional, or other applicable written agreement, FCGI will delete, de-identify, anonymize, dissociate, or otherwise appropriately handle Personal Data associated with the Account that FCGI is not legally permitted or required to retain.

Where an Account was established through Sign in with Apple or another third-party authentication service, FCGI may perform any token revocation, account disassociation, or other deletion-related procedure required by the applicable platform or authentication provider.

Account deletion may result in permanent loss of Account-dependent information, functionality, or benefits.

Once deletion has been completed, FCGI may be unable to restore information that has been deleted or lawfully de-identified.

25.1 EFFECT OF ACCOUNT DELETION

Deleting an Account may permanently prevent FCGI from restoring or providing:

cloud-saved gameplay;
Account history;
personalized gameplay history;
Account preferences;
synchronized information;
customized Account settings;
personalized historical analytics;
Account-linked scores or achievements;
multiplayer information associated with the deleted Account;
competition information;
rewards;
promotional entitlements;
subscription-linked information;
educational information associated with an individual Account;
Account-specific purchases or entitlements that cannot otherwise be restored through Apple; or
other Account-dependent functionality.

A user requesting deletion is responsible for understanding that deletion may be irreversible.

FCGI is not required to recreate information that was lawfully deleted in response to a valid deletion request.

25.2 ACCOUNT DELETION DOES NOT NECESSARILY ERASE HISTORICAL EVENTS

Deletion of an FCGI Account does not necessarily require deletion or alteration of every historical event associated with the Account.

Subject to applicable law, FCGI may preserve historical information reasonably necessary to maintain:

game history;
scores;
achievements;
rankings;
leaderboard integrity;
competition records;
reward records;
educational reporting;
statistical history;
transaction records;
subscription records;
fraud-prevention records;
security records;
abuse-prevention records;
promotional-redemption history;
dispute records;
legal records;
evidentiary records; or
other legitimate historical records.

For example, deletion of an Account does not necessarily require FCGI to recalculate a completed competition, alter another player's historical ranking, erase the historical fact that a game was played, remove a legitimately earned achievement, invalidate historical statistical information, or otherwise rewrite legitimate historical events solely because the Account associated with those events was subsequently deleted.

Where applicable law requires deletion of Personal Data identifying the former Account holder, FCGI may preserve the underlying historical event only to the extent continued retention is legally permitted.

25.3 INFORMATION THAT MAY BE RETAINED AFTER ACCOUNT DELETION

Subject to applicable law and the specialized FERPA and COPPA provisions of this Privacy Policy, FCGI may retain information following Account deletion where reasonably necessary or legally permitted, including:

historical gameplay records;
scores;
achievements;
leaderboard entries;
competition records;
reward records;
transaction records;
subscription records;
entitlement records;
accounting and tax records;
refund and chargeback records;
security records;
fraud-prevention records;
abuse-prevention records;
records concerning cheating or manipulation;
promotional-redemption records;
customer-support records where continued retention is lawful and reasonably necessary;
school or educational records where continued retention is authorized by applicable law and the applicable educational relationship;
aggregated information;
anonymized information;
lawfully de-identified information;
statistical information;
legal records;
evidence;
records subject to litigation, anticipated-litigation, regulatory, investigative, or other lawful preservation holds; and
other information FCGI is permitted or required by applicable law to retain.

The continued retention of a record does not authorize FCGI to continue using the record for purposes inconsistent with the reason the information is lawfully retained.

25.4 PERSONAL DATA DELETION REQUESTS THAT DO NOT REQUIRE ACCOUNT DELETION

Where applicable law provides a right to request deletion of particular Personal Data without requiring deletion of the entire Account, a user may submit the applicable request through a method made available by FCGI or in writing to:

privacy@fullcolorgames.com

FCGI may verify the requester's identity and authority before acting upon the request.

Where legally required and technically reasonably practicable, FCGI may delete the applicable Personal Data while maintaining the remainder of the Account.

If the requested deletion would make a particular Account-dependent feature impossible to provide, FCGI may disable, restrict, or discontinue the affected feature to the extent permitted by applicable law.

Nothing in this Section requires FCGI to delete information that applicable law permits or requires FCGI to retain.

25.5 SCHOOL AND STUDENT DELETION REQUESTS

An authorized school, educational institution, parent, legal guardian, eligible student, or other legally authorized person may submit an applicable deletion request concerning student Personal Data.

FCGI may take reasonable measures to verify the identity and authority of the requester before acting upon the request.

School and student deletion requests are subject to the Children, Students, Schools, Parents, and Guardians provisions of this Privacy Policy, including the FERPA and COPPA provisions in Sections 14.10 through 14.31, applicable law, and any binding School / Institutional Data Protection and FERPA Addendum or other applicable written agreement.

Where FERPA, COPPA, another applicable law, or a binding agreement requires FCGI to return, delete, destroy, or otherwise cease maintaining personally identifiable student information, FCGI will comply with the applicable requirement.

FCGI's general interest in preserving game history, scoring systems, leaderboards, achievements, competitions, rewards, educational reporting, statistical history, fraud-prevention records, or security records does not override an applicable legal or contractual requirement to delete or destroy personally identifiable student information.

Where legally permitted, FCGI may preserve an underlying historical game, score, achievement, statistical, educational, competition, security, or analytical record after the information has been lawfully aggregated, anonymized, de-identified, dissociated, or otherwise transformed so that continued retention is permitted by applicable law.

25.6 PARENTAL AND GUARDIAN DELETION REQUESTS

Where applicable law provides a parent or legal guardian with authority to request deletion of Personal Data concerning a child, FCGI will provide a reasonable method for submitting the request.

Requests may be submitted in writing to:

privacy@fullcolorgames.com

FCGI may use reasonable procedures to verify the requester's identity, relationship to the child, and legal authority before providing access to or deleting information concerning the child.

Nothing in this Section limits any additional rights provided under the COPPA provisions of this Privacy Policy or other applicable law.

25.7 SECURITY AND FRAUD PREVENTION DURING DELETION

FCGI may delay completion of a deletion request for the period reasonably necessary and legally permitted to authenticate the requester, investigate suspected fraud, prevent unauthorized deletion, protect an Account from takeover, comply with legal obligations, or preserve information subject to a lawful hold.

FCGI may maintain a limited record that a deletion request occurred where reasonably necessary for compliance, security, fraud prevention, dispute resolution, or evidentiary purposes and where permitted by applicable law.

A retained record of a deletion request does not authorize FCGI to recreate or reactivate a deleted Account without an appropriate lawful basis.

25.8 DELETION AND THIRD-PARTY SERVICES

Where FCGI has provided Personal Data to a Service Provider acting on FCGI's behalf and applicable law requires deletion of that information, FCGI will take reasonable measures required by applicable law to cause the applicable information to be deleted, returned, de-identified, or otherwise appropriately handled by the Service Provider.

This provision does not require FCGI to delete information independently maintained by a third party acting under its own legal authority where FCGI does not control the applicable information and applicable law does not impose that obligation upon FCGI.

Information independently maintained by Apple, Meta/Facebook, or another third-party service used directly by the user may also be subject to the third party's own deletion procedures, terms, and privacy practices.

25.9 COMPLETION OF ACCOUNT DELETION

FCGI will process a valid Account-deletion request within the period required by applicable law or applicable platform requirements.

Where immediate deletion is not required and additional time is reasonably necessary for verification, security, fraud prevention, legal compliance, technical processing, backup management, or another legally permitted reason, FCGI may complete the deletion within the additional period permitted by applicable law.

Information remaining temporarily in backup, disaster-recovery, archival, or security systems after deletion from active systems will be handled in accordance with applicable law and FCGI's applicable retention and security procedures.

FCGI may prevent information scheduled for deletion from being returned to ordinary active use except where restoration is legally permitted and reasonably necessary for security, disaster recovery, legal compliance, or another lawful purpose.

26. INTERNATIONAL DATA PROCESSING AND TRANSFERS

FCGI is a United States company.

FCGI currently uses cloud infrastructure located in the United States for its primary backend operations.

Users may access the Service from countries and territories throughout the world.

Accordingly, Personal Data may be transferred to, stored in, accessed from, or otherwise processed in the United States or another jurisdiction different from the jurisdiction in which the user is located.

The privacy and data-protection laws of the United States or another processing jurisdiction may differ from those of the user's home jurisdiction.

Where applicable law requires FCGI to implement a recognized transfer mechanism, contractual safeguard, adequacy mechanism, supplementary safeguard, or other measure before transferring Personal Data internationally, FCGI will use an applicable lawful mechanism.

As the Service grows, FCGI may use additional cloud infrastructure, content-delivery networks, caching providers, verification providers, security providers, or other technical infrastructure in additional geographic regions where reasonably necessary to improve performance, availability, security, latency, or reliability.

FCGI will handle international transfers of Personal Data in accordance with applicable law.

27. PRIVACY RIGHTS

Privacy rights differ according to jurisdiction.

Depending upon applicable law and the circumstances, a user may have the right to request that FCGI:

confirm whether FCGI processes Personal Data concerning the user;
provide access to Personal Data;
provide information concerning categories of Personal Data collected;
provide information concerning purposes of processing;
correct inaccurate Personal Data;
complete incomplete Personal Data;
delete Personal Data;
restrict particular processing;
object to particular processing;
provide portable Personal Data in an applicable format;
withdraw consent where processing is based upon consent;
opt out of certain advertising or legally regulated disclosures;
obtain information concerning categories of recipients;
appeal certain privacy-request decisions where applicable; or
exercise another privacy right provided by applicable law.

Not every right applies to every user, every category of information, or every circumstance.

FCGI may deny, limit, or modify a request where permitted or required by applicable law, including where FCGI cannot reasonably verify the requester, an exception applies, information must be retained, disclosure would adversely affect another person's rights, or the request is otherwise outside the scope of the applicable legal right.

27.1 HOW TO EXERCISE PRIVACY RIGHTS

Privacy requests may be submitted in writing to:

privacy@fullcolorgames.com

The request should identify the nature of the privacy right being exercised and provide information reasonably sufficient for FCGI to identify the relevant account or information.

Users should not send passwords, complete payment-card numbers, government identification numbers, or other unnecessary sensitive information with an initial request.

27.2 VERIFICATION

FCGI may take reasonable measures to verify a requester's identity and authority before granting access to, correcting, disclosing, or deleting Personal Data.

Verification measures may vary according to:

the sensitivity of the information;
the nature of the request;
the account involved;
the risk of unauthorized disclosure or deletion;
the information already maintained by FCGI; and
applicable law.

FCGI may request additional information where reasonably necessary to verify the request.

FCGI will not intentionally request more Personal Data than reasonably necessary for verification.

27.3 AUTHORIZED AGENTS

Where applicable law permits an authorized agent to submit a privacy request on behalf of another person, FCGI may require reasonable evidence of the agent's authority and may independently verify the identity of the person whose rights are being exercised where permitted by law.

27.4 NON-DISCRIMINATION

FCGI will not unlawfully discriminate against a user for exercising a privacy right provided by applicable law.

This does not prevent FCGI from restricting or terminating functionality that cannot reasonably be provided without information that the user has lawfully requested FCGI to delete or cease processing.

For example, deletion of a registered account may make cloud restoration, account synchronization, personalized historical analytics, or other account-dependent functionality unavailable.

28. EUROPEAN ECONOMIC AREA, EUROPEAN UNION, AND UNITED KINGDOM PRIVACY INFORMATION

Where the European Union General Data Protection Regulation, United Kingdom GDPR, or another substantially similar data-protection regime applies to FCGI's processing, FCGI will process Personal Data using an applicable lawful basis.

28.1 DATA CONTROLLER

Except where otherwise stated or where another party independently determines the purposes and means of processing, Full Color Games, Inc. is the controller of Personal Data processed for FCGI's own purposes under this Privacy Policy.

Full Color Games, Inc.
5348 Vegas Dr.
Las Vegas, NV 89108
United States

privacy@fullcolorgames.com

28.2 LAWFUL BASES FOR PROCESSING

Depending upon the processing activity, FCGI may rely upon one or more of the following lawful bases:

CONTRACTUAL NECESSITY

FCGI may process information where reasonably necessary to provide an account, purchased service, subscription, multiplayer feature, competition, reward, promotion, educational program, customer support service, or other functionality requested by the user.

LEGITIMATE INTERESTS

FCGI may process information where reasonably necessary for legitimate interests that are not overridden by applicable privacy rights.

These interests may include:

operating and improving the Service;
maintaining game integrity;
protecting accounts;
preventing fraud;
detecting cheating;
maintaining security;
preventing abuse;
authenticating sessions;
protecting scores and achievements;
maintaining leaderboards;
diagnosing technical problems;
understanding product performance;
providing customer support;
protecting FCGI's legal rights;
maintaining appropriate business records; and
protecting users and other persons.

CONSENT

FCGI may rely upon consent where consent is the applicable legal basis.

Examples may include certain device permissions, optional precise-location functionality, certain marketing communications, or another processing activity for which applicable law requires consent.

Where processing is based upon consent, the user may withdraw that consent subject to applicable law.

LEGAL OBLIGATION

FCGI may process information where necessary to comply with an applicable legal obligation.

VITAL INTERESTS OR OTHER LAWFUL BASES

FCGI may rely upon another lawful basis recognized by applicable law where appropriate to the circumstances.

28.3 EEA, EU, AND UK RIGHTS

Subject to applicable law, individuals within the EEA, European Union, or United Kingdom may have rights including:

access;
rectification;
erasure;
restriction;
objection;
portability;
withdrawal of consent; and
the right to lodge a complaint with the competent data-protection supervisory authority.

The availability and scope of a particular right depend upon the applicable circumstances and lawful basis for processing.

28.4 CHILDREN IN EUROPE AND THE UNITED KINGDOM

FCGI recognizes that applicable rules concerning children's consent and online services differ among jurisdictions.

FCGI does not assume that a single global age threshold determines whether a child may independently consent to every form of Personal Data processing.

Where parental, guardian, school, institutional, or other authorization is required under applicable law, FCGI will require the applicable authorization or limit the relevant processing as required by law.

FCGI seeks to apply data minimization and heightened privacy protections to school-authorized and child-directed processing as described elsewhere in this Privacy Policy.

28.5 EEA AND UK REPRESENTATION

FCGI is established in the United States and currently does not maintain an establishment in the European Economic Area or United Kingdom.

Applicable European Union or United Kingdom data-protection law may require a controller or processor located outside the applicable jurisdiction to designate a representative within that jurisdiction under specified circumstances, subject to applicable exceptions.

FCGI will designate and identify any European Union, EEA, United Kingdom, or other privacy representative required by applicable law.

The absence of a representative identified in this Privacy Policy does not limit any right available to an individual under applicable law or prevent an individual from contacting FCGI directly at:

privacy@fullcolorgames.com

29. UNITED STATES STATE PRIVACY RIGHTS

Residents of certain United States jurisdictions may have additional privacy rights under applicable state law.

Depending upon the jurisdiction and whether the applicable law applies to FCGI or the particular processing activity, these rights may include:

knowing or confirming whether Personal Data is processed;
accessing Personal Data;
correcting Personal Data;
deleting Personal Data;
obtaining a portable copy of Personal Data;
obtaining information concerning categories of Personal Data;
obtaining information concerning categories of recipients;
opting out of a sale of Personal Data;
opting out of targeted advertising;
opting out of certain profiling;
limiting certain uses of sensitive Personal Data;
appealing a denied request; or
exercising another right provided by applicable state law.

FCGI does not currently sell Personal Data.

FCGI will honor applicable state privacy rights where legally required.

30. CALIFORNIA PRIVACY INFORMATION

California residents may have rights under applicable California privacy laws, subject to statutory applicability, definitions, exceptions, and exemptions.

The following disclosures supplement the remainder of this Privacy Policy.

30.1 CATEGORIES OF INFORMATION

Depending upon how a user interacts with the Service, FCGI may collect categories of information that include:

identifiers;
contact information;
internet or other electronic-network activity;
device and technical information;
approximate or, where affirmatively permitted, precise geolocation information;
commercial or transaction information;
gameplay and user-content information;
account information;
educational information processed through applicable school functionality;
customer-support information; and
inferences or segmentation reasonably generated from Service activity for the operational purposes described in this Privacy Policy.

FCGI does not intentionally collect biometric identifiers, health information, Social Security numbers, government identification numbers, or bank-account information as part of ordinary Full Color® Solitaire functionality.

30.2 SOURCES AND PURPOSES

FCGI obtains information from sources described throughout this Privacy Policy, including:

users;
devices;
gameplay;
FCGI websites and applications;
schools and institutions;
Apple and supported platform services;
service providers; and
other sources directed or authorized by the user.

FCGI uses the information for the business and commercial purposes described throughout this Privacy Policy.

30.3 SALE AND SHARING

FCGI does not currently sell Personal Data.

FCGI does not currently use IDFA.

FCGI does not currently provide user-supplied FCGI registration information to third-party advertising networks for cross-context behavioral advertising.

Where California law treats a future disclosure or use of Personal Data as a “sale” or “sharing,” FCGI will provide the notices, opt-out mechanisms, consent procedures, or other rights required by applicable law before engaging in that activity.

FCGI does not knowingly sell or share Personal Data concerning children or students in a manner prohibited by applicable law.

FCGI does not treat a sponsor’s payment for a promotion, complimentary subscription, competition, reward, educational program, branded background, promotional code, or other benefit as authorization to receive the user’s Personal Data.

30.4 CALIFORNIA PRIVACY RIGHTS

Subject to applicable law and applicable exceptions, California residents may have the right to:

know the categories of Personal Data FCGI collects;
know the categories of sources from which Personal Data is collected;
know the business or commercial purposes for collecting, using, disclosing, selling, or sharing Personal Data;
know the categories of third parties to whom Personal Data is disclosed;
request access to specific pieces of Personal Data maintained about them;
request correction of inaccurate Personal Data;
request deletion of Personal Data;
opt out of the sale or sharing of Personal Data where applicable;
limit certain uses or disclosures of sensitive Personal Data where applicable;
receive information concerning applicable data practices; and
exercise applicable privacy rights without unlawful discrimination.

The availability and scope of a particular right depends upon applicable law, the nature of the information, the purpose for which FCGI maintains it, and any applicable exception.

FCGI may retain information notwithstanding a deletion request where retention is permitted or required by applicable law, including for security, fraud prevention, transaction records, game integrity, historical scoring, leaderboards, educational reporting, legal compliance, dispute resolution, litigation, anticipated litigation, regulatory matters, or other lawful purposes described in this Privacy Policy.

30.5 CALIFORNIA REQUESTS

California privacy requests may be submitted in writing to:

privacy@fullcolorgames.com

A request should contain enough information to allow FCGI to understand and reasonably verify the request.

FCGI may request additional information where reasonably necessary to verify the identity or authority of the requester.

An authorized agent may submit a request where permitted by applicable law. FCGI may require evidence that the agent is authorized to act for the applicable user.

FCGI will respond within the period required by applicable law.

30.6 CALIFORNIA MINORS

FCGI does not knowingly sell Personal Data concerning minors in violation of applicable California law.

FCGI does not knowingly use school-authorized student Personal Data for unrelated behavioral advertising, unrelated commercial profiling, or other purposes prohibited by applicable law.

Where a child or minor participates through a school or institutional program, the additional protections described in the Children, Students, Schools, Parents, and Guardians provisions of this Privacy Policy apply.

30.7 SHINE THE LIGHT

California residents may have rights under California Civil Code Section 1798.83 concerning certain disclosures of Personal Data to third parties for their own direct-marketing purposes.

FCGI does not currently disclose Personal Data to third parties for their own direct-marketing purposes in the manner contemplated by that law.

Questions may be submitted to:

privacy@fullcolorgames.com

31. OTHER UNITED STATES STATE PRIVACY RIGHTS

Residents of certain United States states may have privacy rights under state privacy laws applicable to FCGI.

Depending upon the jurisdiction and applicable thresholds, these rights may include:

access;
confirmation of processing;
correction;
deletion;
portability;
obtaining a copy of Personal Data;
opting out of targeted advertising;
opting out of the sale of Personal Data;
opting out of certain profiling;
limiting certain sensitive-data processing;
withdrawing consent where consent is the applicable basis for processing; and
appealing certain decisions concerning privacy requests.

FCGI will provide rights required by applicable state law to users entitled to those rights.

FCGI does not currently sell Personal Data.

FCGI does not currently use IDFA.

FCGI does not currently operate conventional third-party behavioral advertising networks within Full Color® Solitaire.

Sponsor branding associated with a voluntarily redeemed promotion, complimentary subscription, competition, reward, educational program, or similar benefit does not itself constitute disclosure of the user’s FCGI account information to the sponsor.

Requests may be submitted to:

privacy@fullcolorgames.com

32. RIGHTS OF USERS OUTSIDE THE UNITED STATES

Privacy rights vary by jurisdiction.

Users located outside the United States may have rights under local law concerning:

access;
correction;
deletion;
restriction;
objection;
portability;
consent withdrawal;
information concerning processing;
complaints to a privacy or data-protection authority; or
other rights established by applicable law.

FCGI will honor applicable rights where required by the law governing the applicable user and processing activity.

Nothing in this Privacy Policy is intended to restrict a privacy right that cannot lawfully be waived.

33. INTERNATIONAL DATA TRANSFERS

FCGI is based in the United States.

FCGI currently uses AWS infrastructure located in the United States.

Personal Data collected from users outside the United States may therefore be transferred to, processed in, or stored in the United States.

FCGI may also use service providers, content-delivery networks, communications providers, security providers, customer-support providers, and other infrastructure located in jurisdictions different from the user’s location.

Privacy and data-protection laws in those jurisdictions may differ from those in the user’s home jurisdiction.

Where applicable law requires safeguards for an international transfer of Personal Data, FCGI will use legally recognized mechanisms or other appropriate safeguards required for the applicable transfer.

Such safeguards may include contractual protections, recognized transfer mechanisms, adequacy mechanisms, technical controls, organizational controls, or other legally permitted safeguards.

FCGI may modify its infrastructure as the Service grows, including by adding regional hosting, content-delivery, verification, security, or performance providers.

FCGI will update its practices where required by applicable law.

34. DATA RETENTION, EDUCATIONAL RECORDS, AND SPECIALIZED RETENTION REQUIREMENTS

This Section supplements Section 24 and establishes additional retention requirements applicable to children, students, schools, educational information, FERPA-protected information, COPPA-covered Personal Data, and other information subject to specialized legal or contractual retention requirements.

If a provision of this Section conflicts with a general retention provision elsewhere in this Privacy Policy, this Section controls with respect to the information governed by this Section to the extent required by applicable law or a binding written agreement.

Nothing in this Section authorizes FCGI to retain Personal Data where FERPA, COPPA, another applicable law, a binding regulatory requirement, or a binding School / Institutional Data Protection and FERPA Addendum or other written agreement requires FCGI to return, delete, destroy, de-identify, or otherwise cease maintaining that Personal Data.

Subject to those requirements, FCGI may retain information for the period reasonably necessary to provide the applicable Service and fulfill the lawful purposes described in this Privacy Policy.

34.1 FERPA-PROTECTED INFORMATION

FERPA and its applicable implementing regulations;
the FERPA exception or other lawful authority applicable to the disclosure;
the purpose for which the information was disclosed;
the lawful instructions and direct control of the applicable educational agency or institution where required;
applicable federal, state, or local student-privacy requirements; and
any binding School / Institutional Data Protection and FERPA Addendum or other applicable written agreement.

FCGI's general rights or interests in preserving game history, scores, achievements, leaderboards, competitions, rewards, educational reporting, statistical history, fraud-prevention information, security information, or other historical records do not override an applicable requirement to return, delete, or destroy personally identifiable information from education records.

Where FERPA or another applicable requirement permits continued retention after de-identification, FCGI may preserve the underlying historical, statistical, gameplay, scoring, achievement, educational, competition, security, or analytical record after taking measures sufficient to render the retained information no longer personally identifiable under the applicable legal standard.

Where a particular FERPA exception imposes specific written-agreement, retention, destruction, redisclosure, access, or other requirements, the requirements applicable to that particular disclosure control.

34.2 SCHOOL, STUDENT, AND EDUCATIONAL RECORD RETENTION

The applicable school or educational institution may establish legitimate educational, administrative, reporting, historical, or recordkeeping requirements concerning information processed through the Service.

Where FCGI maintains information on behalf of a school or educational institution, FCGI will process the information subject to applicable law and any binding agreement governing the applicable educational relationship.

A school or educational institution may independently maintain education records according to its own lawful retention obligations and policies.

34.3 COPPA-COVERED CHILDREN'S PERSONAL DATA

FCGI will not retain children's Personal Data indefinitely merely because continued storage is technically possible or potentially useful.

When children's Personal Data is no longer reasonably necessary for the purpose for which it was collected and no other lawful retention basis applies, FCGI will delete the information using reasonable measures designed to protect against unauthorized access to or use of the information in connection with its disposal.

FCGI's general interests in preserving game history, scoring systems, leaderboards, achievements, competitions, rewards, educational reporting, statistical history, fraud-prevention records, or security records do not override an applicable COPPA retention or deletion requirement.

Where permitted by applicable law, FCGI may retain appropriately aggregated, anonymized, or de-identified information that no longer constitutes Personal Data concerning an identifiable child.

34.4 HISTORICAL GAME, SCORE, ACHIEVEMENT, AND COMPETITION RECORDS

FCGI's games and related Services may create historical records whose accuracy depends upon preservation of events that have already occurred.

Such records may include:

completed games;
game or seed identifiers;
scores;
achievements;
rankings;
leaderboard positions;
competition participation;
competition results;
rewards;
promotional participation;
educational results;
statistical history;
fraud-prevention information; and
security or game-integrity information.

Deletion of Personal Data does not necessarily require alteration of an otherwise lawful historical event.

Subject to FERPA, COPPA, other applicable law, and any binding agreement, FCGI may preserve an underlying historical record where reasonably necessary to maintain the accuracy and integrity of the applicable game, scoring system, leaderboard, achievement, competition, reward, educational report, statistical history, fraud-prevention system, or security record.

Where FCGI is legally or contractually required to delete identifying Personal Data associated with the historical record, continued preservation of the underlying record is permitted only to the extent allowed by applicable law.

Where reasonably practicable and legally permitted, FCGI may preserve the historical record after deleting, anonymizing, aggregating, de-identifying, pseudonymizing, or dissociating information identifying the applicable individual.

34.5 DE-IDENTIFIED AND AGGREGATED EDUCATIONAL INFORMATION

Subject to FERPA, COPPA, and other applicable law, FCGI may retain and use appropriately aggregated or de-identified educational information for purposes including:

improving Full Color® Solitaire;
improving educational functionality;
evaluating game and educational performance;
developing educational tools;
statistical analysis;
benchmarking;
research;
product development;
curriculum-support analysis;
evaluating instructional methods;
analyzing generalized performance trends;
evaluating effectiveness of educational tools;
improving GameKit, PlayKit, CompetitionKit, RewardsKit, and other FCGI educational products; and
improving FCGI products and services generally.

For example, FCGI may analyze appropriately aggregated or de-identified information concerning average gameplay scores, generalized performance improvements, grade-level performance, instructional outcomes, curriculum effectiveness, or use of particular educational methods where individual students are not personally identifiable.

FCGI will not represent information as de-identified where FCGI reasonably knows that the information remains personally identifiable under the applicable legal standard.

34.6 LEGAL AND CONTRACTUAL DELETION REQUIREMENTS CONTROL

No general retention provision in this Privacy Policy authorizes FCGI to disregard a mandatory deletion, destruction, return, or de-identification requirement imposed by applicable law or a binding written agreement.

Where applicable law or a binding agreement requires deletion or destruction of personally identifiable information while permitting continued retention of appropriately de-identified information, FCGI may preserve the permitted de-identified information.

Where applicable law requires destruction of the underlying information notwithstanding de-identification or another retention interest, FCGI will comply with the applicable requirement.

34.7 SCHOOL TERMINATION OR EXPIRATION

When a school or institutional relationship terminates or expires, FCGI may take reasonable steps to:

discontinue access by the institution or its authorized users;
return information where required;
permit an authorized institution to retrieve information where applicable;
delete information where required;
de-identify information where permitted;
preserve information where legally permitted or required;
maintain records necessary to document FCGI's compliance;
preserve information subject to a lawful legal, regulatory, security, fraud, or evidentiary hold; and
otherwise process the information according to applicable law and the applicable school or institutional agreement.

Termination of a school or institutional relationship does not automatically authorize FCGI to destroy records that applicable law or a binding agreement requires FCGI to preserve.

It likewise does not authorize FCGI to retain personally identifiable student information that applicable law or a binding agreement requires FCGI to return, delete, or destroy.

34.8 WRITTEN RETENTION AND DELETION POLICIES

Where required by COPPA or another applicable law, FCGI will maintain an internal written retention and deletion policy applicable to the covered Personal Data.

Such policies may establish:

categories of information;
purposes for retention;
applicable retention periods or criteria;
deletion or destruction procedures;
de-identification procedures;
legal-hold procedures;
security requirements;
backup and archival treatment;
responsibilities for implementation; and
other procedures required by applicable law.

The existence of an internal retention schedule does not reduce any privacy right or deletion obligation that applicable law requires FCGI to provide.

34.9 RELATIONSHIP TO SECTION 24

Section 24 establishes FCGI's general data-retention framework.

This Section establishes additional protections and specialized requirements for educational, student, child, FERPA, COPPA, and related information.

The provisions should be read together.

Where both Sections apply, FCGI will apply the more specific requirement governing the applicable information.

Where applicable mandatory law provides greater protection than either Section, the mandatory legal requirement controls to the extent required by law.

35. SPECIALIZED DELETION, RETURN, DE-IDENTIFICATION, AND PRESERVATION REQUIREMENTS

This Section supplements Section 25 and establishes additional requirements concerning deletion, return, destruction, de-identification, preservation, and related handling of Personal Data subject to FERPA, COPPA, school or institutional agreements, legal holds, security requirements, service-provider processing, backup systems, or other specialized legal or contractual requirements.

If a provision of this Section conflicts with a general deletion provision elsewhere in this Privacy Policy, this Section controls with respect to information governed by this Section to the extent required by applicable law or a binding written agreement.

Nothing in this Section authorizes FCGI to retain Personal Data where applicable law, a binding regulatory requirement, or a binding written agreement requires FCGI to return, delete, destroy, de-identify, or otherwise cease maintaining that Personal Data.

35.1 FERPA AND EDUCATION-RECORD DELETION

Where FCGI receives or maintains personally identifiable information from education records subject to FERPA, deletion, return, destruction, de-identification, or continued retention will be governed by:

FERPA and its applicable implementing regulations;
the FERPA exception or other lawful authority applicable to the disclosure;
the purpose for which the information was disclosed;
the lawful instructions and direct control of the applicable educational agency or institution where required;
applicable federal, state, or local student-privacy requirements; and
any binding School / Institutional Data Protection and FERPA Addendum or other applicable written agreement.

Where FERPA, another applicable law, or a binding agreement requires FCGI to return, delete, or destroy personally identifiable information from education records, FCGI will take reasonable measures to satisfy the applicable requirement within the period required by law or the applicable binding agreement.

FCGI's interest in preserving gameplay history, scores, achievements, rankings, leaderboards, competitions, rewards, educational reporting, statistical information, security records, fraud-prevention records, or other historical information does not override an applicable requirement to return, delete, or destroy personally identifiable information from education records.

Where legally permitted, FCGI may preserve an underlying historical, statistical, gameplay, scoring, achievement, educational, competition, security, or analytical record after removing or transforming information so that the retained information is no longer personally identifiable under the applicable legal standard.

35.2 COPPA AND CHILDREN'S PERSONAL DATA DELETION

Where COPPA applies, FCGI will provide deletion and cessation-of-collection rights required by COPPA.

FCGI will delete children's Personal Data when the information is no longer reasonably necessary to fulfill the specific purpose for which it was collected unless continued retention is otherwise permitted or required by applicable law.

Where a verified parent, legal guardian, or other person having authority under applicable law validly requests deletion of a child's Personal Data, FCGI will process the request in accordance with COPPA and other applicable law.

FCGI may take reasonable measures to verify the identity and authority of the requester before providing access to or deleting information concerning a child.

Nothing in FCGI's general game-history, scoring, leaderboard, achievement, competition, reward, educational-reporting, statistical, security, or fraud-prevention retention practices overrides an applicable COPPA deletion requirement.

Where permitted by applicable law, FCGI may retain appropriately aggregated, anonymized, or de-identified information that no longer constitutes Personal Data concerning an identifiable child.

35.3 SCHOOL AND INSTITUTIONAL REQUESTS

An authorized school, school district, educational institution, or other qualifying educational organization may request return, deletion, destruction, correction, restriction, or de-identification of information maintained by FCGI on its behalf where permitted or required by applicable law or a binding agreement.

FCGI may take reasonable measures to verify:

the identity of the requester;
the requester's relationship to the institution;
the requester's authority to act for the institution;
the scope of the request; and
the information to which the request applies.

FCGI may coordinate with the applicable school or institution where necessary to avoid unauthorized deletion, alteration, or disclosure of education records.

Where a school or institutional agreement establishes a specific return, deletion, destruction, transition, or retrieval procedure, FCGI will follow the binding procedure to the extent required by that agreement and applicable law.

35.4 PARENT, GUARDIAN, AND ELIGIBLE-STUDENT REQUESTS

A parent, legal guardian, eligible student, or other legally authorized person may submit a request concerning Personal Data or education records where applicable law grants that person the applicable right.

Requests may be submitted in writing to:

privacy@fullcolorgames.com

Where the applicable information constitutes an education record controlled by a school or educational institution, FCGI may coordinate the request with or direct the requester to the applicable school or institution where appropriate because the school or institution may be responsible for determining and administering the applicable FERPA right.

FCGI will not disclose, alter, or delete student information merely because a person claims to be a parent, guardian, eligible student, teacher, administrator, or other authorized person.

FCGI may require reasonable verification of identity and authority before acting upon the request.

35.5 DE-IDENTIFICATION IN LIEU OF DESTRUCTION WHERE LEGALLY PERMITTED

Where applicable law or a binding agreement permits FCGI to satisfy an applicable privacy or retention requirement through de-identification rather than destruction of the underlying record, FCGI may de-identify, aggregate, anonymize, pseudonymize, dissociate, or otherwise transform the information as permitted by the applicable legal standard.

FCGI may preserve the resulting information for lawful purposes including:

historical game integrity;
statistical analysis;
research;
benchmarking;
product development;
educational analysis;
curriculum-support analysis;
game balancing;
security analysis;
fraud-prevention analysis;
performance evaluation;
evaluation of educational tools;
evaluation of instructional methods; and
improvement of FCGI products and services.

FCGI will not characterize information as de-identified or anonymous where FCGI reasonably knows that the information remains personally identifiable under the applicable legal standard.

35.6 LEGAL HOLDS AND PRESERVATION OBLIGATIONS

Subject to applicable law, FCGI may suspend ordinary deletion, destruction, or modification of information where reasonably necessary to:

comply with a litigation hold;
preserve evidence;
prepare for reasonably anticipated litigation;
respond to a subpoena, court order, warrant, or other lawful legal process;
respond to a regulatory or governmental investigation;
establish, exercise, or defend legal claims;
investigate fraud;
investigate cheating or game manipulation;
investigate a security incident;
investigate unauthorized access;
investigate abuse;
resolve a competition, promotion, reward, eligibility, payment, refund, or chargeback dispute;
enforce FCGI's Terms, licenses, rules, or other agreements; or
satisfy another lawful preservation obligation.

Information preserved under a legal or evidentiary hold may be segregated, access-restricted, or removed from ordinary operational use where reasonably appropriate.

A legal hold does not authorize FCGI to use preserved Personal Data for unrelated purposes.

Where applicable law requires deletion notwithstanding an asserted preservation interest, the applicable mandatory legal requirement controls.

35.7 FRAUD, SECURITY, AND ABUSE RECORDS

Subject to applicable law, FCGI may retain limited information reasonably necessary to identify, prevent, investigate, document, or defend against:

fraud;
account theft;
unauthorized access;
cheating;
score manipulation;
achievement manipulation;
leaderboard manipulation;
duplicate or unauthorized promotional redemption;
location circumvention;
automated abuse;
bots;
injection attacks;
attempted database manipulation;
unauthorized software modification;
exploitation of vulnerabilities;
security incidents;
abuse of competitions or rewards; or
other threats to FCGI, its users, schools, institutions, systems, games, data, or services.

Where a user validly exercises a deletion right, FCGI will limit continued retention of such information to the extent permitted or required by applicable law.

Deletion of an Account does not require FCGI to destroy a lawful security record where continued retention is reasonably necessary and legally permitted to prevent recurrence of fraud, abuse, unauthorized access, or other security threats.

35.8 SERVICE PROVIDERS AND SUBPROCESSORS

Where FCGI has disclosed or made Personal Data available to a Service Provider acting on FCGI's behalf and applicable law or a binding agreement requires deletion, return, destruction, restriction, or de-identification of that information, FCGI will take the measures required by applicable law or the binding agreement concerning the applicable Service Provider.

Such measures may include directing the Service Provider to:

delete the applicable Personal Data;
return the applicable Personal Data;
cease processing the applicable Personal Data;
restrict further processing;
de-identify the applicable Personal Data; or
provide confirmation or other appropriate assurance concerning completion where required.

FCGI will not authorize a Service Provider to retain FCGI-provided Personal Data for the provider's unrelated advertising, marketing, profiling, sale, or other unrelated commercial purposes.

This Section does not require FCGI to cause deletion of information independently maintained by a third party acting under its own legal authority where FCGI does not control the applicable information and applicable law does not impose that obligation upon FCGI.

35.9 APPLE AND OTHER USER-DIRECTED THIRD-PARTY SERVICES

Information independently maintained by Apple, Meta/Facebook, or another third-party service that a user independently elects to use may be subject to that third party's own privacy policy, account controls, retention requirements, and deletion procedures.

Deletion of an FCGI Account does not necessarily delete an independent Apple, Facebook, or other third-party account.

Where FCGI is required by applicable platform rules to revoke an authentication token, disassociate an FCGI Account, or perform another deletion-related action concerning a supported third-party authentication service, FCGI will perform the applicable action.

Nothing in this Section limits FCGI's obligations concerning Personal Data processed by a Service Provider acting on FCGI's behalf.

35.10 BACKUPS, ARCHIVES, AND DISASTER-RECOVERY SYSTEMS

Personal Data deleted from active FCGI systems may remain temporarily in backups, archives, disaster-recovery systems, security systems, or other protected storage where immediate deletion is technically impracticable or where continued temporary retention is permitted by applicable law.

Where permitted by applicable law, information remaining in such systems may be retained until:

the applicable backup is overwritten;
the applicable retention cycle expires;
the information can reasonably be deleted;
the applicable archive is destroyed; or
another applicable deletion event occurs.

During that period, FCGI will not intentionally restore deleted Personal Data to ordinary active use except where restoration is reasonably necessary and legally permitted for:

disaster recovery;
security;
legal compliance;
investigation of an incident;
preservation of evidence; or
another lawful purpose.

Where applicable law or a binding agreement imposes more specific requirements concerning backup deletion or isolation, those requirements control.

35.11 RECORD OF PRIVACY AND DELETION REQUESTS

Subject to applicable law, FCGI may maintain a limited record documenting:

that a privacy request was received;
the nature of the request;
verification performed;
actions taken;
the date of completion;
communications concerning the request; and
other information reasonably necessary to demonstrate compliance, prevent fraud, resolve disputes, or preserve evidence.

Retention of a compliance record does not authorize FCGI to recreate a deleted Account or repurpose deleted Personal Data for unrelated purposes.

35.12 COMPLETION AND RESPONSE PERIODS

FCGI will process valid deletion, return, destruction, de-identification, access, or other privacy requests within the period required by applicable law, applicable platform requirements, or a binding written agreement.

Where applicable law permits an extension because additional time is reasonably necessary, FCGI may use the legally permitted extension and provide any notice required by applicable law.

FCGI may delay action for the period reasonably necessary and legally permitted to:

verify identity;
verify authority;
authenticate the Account;
clarify the scope of the request;
prevent fraud;
prevent unauthorized deletion;
investigate suspected account compromise;
preserve information subject to a lawful hold; or
satisfy another applicable legal requirement.

35.13 RELATIONSHIP TO SECTION 25

Section 25 establishes FCGI's general Account and Personal Data deletion framework.

This Section establishes additional requirements concerning FERPA, COPPA, schools, students, children, legal holds, security records, Service Providers, third-party services, backups, and other specialized deletion circumstances.

The Sections should be read together.

Where both Sections apply, FCGI will apply the more specific requirement governing the applicable information.

Where applicable mandatory law or a binding agreement provides greater protection or imposes a more specific requirement, that requirement controls to the extent required by law or the applicable binding agreement.

36. DATA SECURITY

FCGI uses reasonable administrative, technical, physical, and organizational safeguards designed to protect Personal Data and the Service.

Security measures may include, as appropriate:

access controls;
authentication;
account verification;
encryption;
secure communications;
monitoring;
logging;
fraud detection;
abuse detection;
session validation;
device verification;
network protections;
infrastructure security;
application security;
restricted administrative access;
backup procedures;
incident investigation;
security testing; and
other measures appropriate to the nature of the Service and information involved.

FCGI also uses gameplay, device, session, network, location, account, and technical information where reasonably necessary to detect manipulation, attacks, fraud, injection attempts, unauthorized access, cheating, leaderboard manipulation, achievement manipulation, account theft, duplicate redemptions, or other abuse.

No method of electronic transmission, network communication, application operation, or electronic storage can be guaranteed to be completely secure.

FCGI therefore cannot guarantee absolute security.

Users are responsible for protecting their own account credentials, devices, email accounts, passwords, and authentication methods.

36.1 SECURITY INCIDENTS

If FCGI becomes aware of a security incident involving Personal Data, FCGI will investigate and take steps reasonably appropriate to the circumstances.

Where applicable law requires notification to affected users, regulators, schools, institutions, or other persons, FCGI will provide the required notification within the legally applicable period.

37. LEGAL HOLDS, PUBLIC-AUTHORITY REQUESTS, DISPUTES, FRAUD, AND EVIDENTIARY PRESERVATION

Subject to applicable law, FCGI may preserve information where reasonably necessary in connection with:

actual litigation;
anticipated litigation;
regulatory inquiries;
government investigations;
public-authority requests;
subpoenas;
warrants;
court orders;
legal claims;
Intellectual Property disputes;
fraud investigations;
security investigations;
abuse investigations;
Competition disputes;
promotional disputes;
payment disputes;
refund disputes;
chargebacks;
enforcement of FCGI agreements;
preservation of evidence; or
another legal obligation or legitimate legal interest recognized by applicable law.

FCGI's receipt of legal process or a request from a public authority does not, by itself, establish that the request is valid, enforceable, properly issued, within the requesting authority's jurisdiction, or entitled to the full scope of information requested.

Public-authority requests are subject to the review, challenge, narrowing, data-minimization, documentation, and other procedures described in Section 21.6 and FCGI's applicable internal policies and procedures.

To the extent permitted by applicable law, FCGI may preserve records concerning the request, FCGI's legal review, persons involved in the review or response, communications concerning the request, objections or challenges, information disclosed or withheld, the disposition of the request, and the legal basis for FCGI's response.

Information preserved for these purposes may be segregated or restricted from ordinary operational use where appropriate.

Nothing in this Section requires FCGI to waive attorney-client privilege, attorney work-product protection, common-interest protection, confidentiality rights, security protections, or another applicable privilege or protection.

38. AUTOMATED PROCESSING, FRAUD DETECTION, AND GAME AUTHENTICITY

FCGI may use automated systems, rules, comparisons, analytics, or technical controls to identify activity that may indicate:

fraud;
cheating;
account compromise;
unauthorized access;
automated gameplay;
manipulation;
location circumvention;
duplicate promotion redemption;
abnormal scoring;
achievement manipulation;
leaderboard manipulation;
attempted database manipulation;
injection attacks;
unauthorized software modification; or
another threat to FCGI systems or users.

Such systems may flag activity for additional verification, restrict certain functionality, require authentication, delay a result, invalidate suspicious activity, or refer the matter for human review.

Where applicable law provides rights concerning decisions based solely upon automated processing that produce legal or similarly significant effects, FCGI will provide those rights where applicable.

Ordinary fraud detection, game-integrity checks, score validation, security analysis, or technical authentication do not necessarily constitute legally significant automated decision-making.

VERIFICATION OF INFORMATION

Where permitted by applicable law and with any permission required by the applicable Device or operating system, FCGI may access, collect, receive, use, process, verify, compare, or otherwise process information made available through a User's Contacts or similar Device functionality in connection with the Service.

Such information may include names, telephone numbers, email addresses, identifiers, and other information made available through the applicable permission or functionality.

FCGI may process such information where reasonably necessary or appropriate to provide, administer, authenticate, verify, secure, protect, support or maintain the applicable Service; verify information, identity, eligibility, authority, affiliation, or Account or program-related information; prevent or investigate fraud, abuse, impersonation, unauthorized activity, circumvention, or security threats; satisfy legal, regulatory, contractual, program, or compliance requirements; or otherwise provide functionality requested or authorized by the User.

FCGI does not access Device Contacts through a permission requiring User authorization unless the applicable permission has been granted.

Where the Service permits a User to select, share, communicate with, invite, identify, verify, or otherwise interact with a contact, FCGI may process information reasonably necessary to provide or support the applicable User-initiated functionality.

Users may control applicable Contacts permissions through the controls provided by their Device or operating system. Denying, limiting, modifying, or revoking permission may limit or disable functionality that depends upon access to the applicable information.

FCGI may retain information processed through Contacts functionality for as long as reasonably necessary for the applicable Service, verification, authentication, security, fraud-prevention, compliance, recordkeeping, dispute-resolution, legal, or other lawful purpose described in this Privacy Policy, subject to applicable law.

Where continued retention of identifiable Contacts information is no longer reasonably necessary or otherwise permitted, FCGI may delete, de-identify, aggregate, dissociate, or otherwise process the information in accordance with this Privacy Policy and applicable law.

38.1 CONTACTS-BASED AND OTHER VERIFICATION

FCGI may use information lawfully available to FCGI to verify identity, Account information, eligibility, authority, affiliation, relationships, applications, requests, security, fraud indicators, program integrity and other information relevant to providing, protecting or administering the Service.

Where verification involves information obtained through a User's Device Contacts, the collection, use, disclosure, retention and User controls applicable to that information are governed by Section 9.3.

FCGI may compare information supplied by a User with information lawfully available to FCGI where reasonably necessary to determine whether information supplied in connection with an Account, Game Kit application, eligibility determination, verification request or other FCS Service is authentic, accurate, consistent or sufficient for the applicable purpose.

Verification may be automated, manual or a combination of automated and manual processes.

Verification does not guarantee approval of an Account, Game Kit application, eligibility determination or other request.

FCGI may require additional information or another verification method where information available to FCGI is insufficient, inconsistent, inconclusive or otherwise inadequate for the applicable verification purpose.

39. DO NOT TRACK AND GLOBAL PRIVACY CONTROL

Browser-based “Do Not Track” signals are not interpreted uniformly throughout the industry.

FCGI will respond to legally recognized browser or device-based privacy preference signals where applicable law requires FCGI to do so.

Where a legally recognized Global Privacy Control or similar mechanism applies to FCGI’s processing, FCGI will honor the signal to the extent required by applicable law.

Because FCGI does not currently sell Personal Data and does not currently operate conventional cross-context behavioral advertising through IDFA, some opt-out signals may not change FCGI’s current processing.

40. CHILDREN’S PRIVACY REQUESTS

A parent, legal guardian, school, educational institution, or other legally authorized person may contact FCGI regarding information associated with a child or student.

Requests may concern:

access;
correction;
deletion;
restriction;
withdrawal of authorization;
school account administration;
student identifier changes; or
another legally recognized privacy right.

Requests should be submitted in writing to:

privacy@fullcolorgames.com

FCGI may request information reasonably necessary to verify the identity and legal authority of the person making the request.

FCGI will not disclose a child’s or student’s Personal Data merely because someone claims to be a parent, guardian, teacher, school representative, or other authorized person without reasonable verification where verification is appropriate.

41. CHANGES TO THIRD-PARTY PROVIDERS AND TECHNOLOGY

The technology used to provide online and mobile services changes over time.

FCGI may replace, discontinue, add, or modify cloud providers, analytics tools, support systems, notification services, content-delivery networks, security services, platform technologies, and other service providers.

FCGI will not treat the existence of this provision as authorization to begin a materially different Personal Data practice without complying with applicable privacy law and applicable platform requirements.

If a material change requires additional notice, consent, permission, opt-out rights, App Store disclosures, ATT authorization, contractual safeguards, or other compliance measures, FCGI will implement the applicable requirements before or in connection with the changed practice.

42. CHANGES TO THIS PRIVACY POLICY AND FCGI'S PRIVACY PRACTICES

FCGI RESERVES, TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE SOLE AND EXCLUSIVE RIGHT, IN ITS DISCRETION, AT ANY TIME, TO MODIFY, AMEND, SUPPLEMENT, REVISE, REPLACE, RESTATE, UPDATE, REMOVE, OR OTHERWISE CHANGE THIS PRIVACY POLICY AND FCGI'S PRIVACY PRACTICES.

Such changes may result from, among other things:

changes to the Service;
new or discontinued features;
changes in technology;
changes in FCGI's business operations;
changes in security practices;
changes in fraud-prevention practices;
changes in service providers;
changes in cloud or network infrastructure;
changes in analytics or diagnostic technologies;
changes in school or institutional services;
changes in GameKit, PlayKit, CompetitionKit, or RewardsKit;
changes in competitions, promotions, rewards, or sponsorship programs;
changes in legal or regulatory requirements;
changes in regulatory guidance;
changes in Apple or other applicable platform requirements; or
any other lawful business, operational, technical, security, legal, regulatory, or commercial reason determined appropriate by FCGI.

42.1 NO VESTED RIGHT IN CONTINUATION OF PRIVACY PRACTICES

Except to the extent otherwise required by applicable law or an express written agreement binding upon FCGI, no user acquires a vested, perpetual, or irrevocable contractual right requiring FCGI to continue indefinitely any particular technology, feature, service provider, data-processing method, retention practice, security practice, account functionality, promotional practice, or other privacy practice merely because that practice existed when the user first accessed or used the Service.

FCGI may discontinue or replace a particular processing activity or technology at any time, subject to applicable law.

42.2 EFFECTIVE DATE OF CHANGES

FCGI may make non-material, administrative, technical, clarifying, corrective, organizational, or legally required changes effective upon publication of the revised Privacy Policy or on another date identified by FCGI, to the fullest extent permitted by applicable law.

The "Effective Date" appearing at the beginning of this Privacy Policy identifies the effective date of the current version of this Privacy Policy.

Where FCGI specifies a separate effective date for a particular revision, the revision becomes effective on that specified date, subject to applicable law.

Users are encouraged to review this Privacy Policy periodically.

42.3 NOTICE OF MATERIAL CHANGES

FCGI is not required to provide advance or individualized notice of every amendment to this Privacy Policy unless such notice is required by applicable law, applicable platform requirements, or an express written agreement binding upon FCGI.

Where applicable law or applicable platform requirements require notice of a material change, FCGI will provide the legally or contractually required notice through one or more appropriate methods.

Such notice may include:

an in-app notice;
a notice presented when the Service is opened;
an account notice;
email;
SMS;
push notification;
website notice;
school or institutional communication; or
another legally sufficient method.

42.4 NEW OR MATERIALLY DIFFERENT PROCESSING

FCGI's reservation of amendment rights does not eliminate a consent, authorization, permission, notice, opt-out, or other requirement independently imposed by applicable law or applicable platform requirements.

If FCGI introduces a new or materially different processing activity for which applicable law or applicable platform requirements require:

affirmative consent;
express consent;
parental consent;
school or institutional authorization;
device permission;
App Tracking Transparency authorization;
notice at collection;
an opportunity to opt out;
an opportunity to limit processing; or
another legally required procedure,

FCGI will provide the applicable procedure to the extent required before or in connection with the affected processing.

42.5 CONTINUED USE

Where permitted by applicable law, continued access to or use of the Service following the effective date of a revised Privacy Policy constitutes acknowledgment of the revised Privacy Policy and the privacy practices then applicable to the Service.

Continued use will not be treated as affirmative consent where applicable law independently requires a different or more specific form of consent or authorization.

Where a user declines consent or permission required solely for an optional feature, FCGI may disable or withhold the affected feature without necessarily terminating the user's access to other portions of the Service.

42.6 NO OBLIGATION TO CONTINUE A PARTICULAR FEATURE OR DATA PRACTICE

Nothing in this Privacy Policy requires FCGI to continue offering any particular:

feature;
account functionality;
multiplayer service;
communication method;
promotional program;
sponsor program;
competition;
reward;
educational service;
GameKit;
PlayKit;
CompetitionKit;
RewardsKit;
analytics service;
cloud provider;
SDK;
support provider;
authentication method;
storage method; or
other technology or Service functionality.

FCGI may modify, replace, restrict, suspend, or discontinue such functionality in accordance with the applicable Terms and applicable law.

42.7 NO LIABILITY MERELY FOR LAWFUL AMENDMENT

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, FCGI SHALL NOT INCUR LIABILITY, DAMAGES, PENALTIES, COMPENSATION OBLIGATIONS, OR OTHER RESPONSIBILITY MERELY BECAUSE FCGI LAWFULLY MODIFIES, AMENDS, SUPPLEMENTS, REPLACES, UPDATES, OR DISCONTINUES A PRIVACY PRACTICE, TECHNOLOGY, FEATURE, OR SERVICE IN ACCORDANCE WITH THIS PRIVACY POLICY, THE APPLICABLE TERMS, APPLICABLE PLATFORM REQUIREMENTS, AND APPLICABLE LAW.

Nothing in this Section excludes liability, remedies, notice obligations, consent requirements, or other duties that applicable law does not permit FCGI to exclude, disclaim, or waive.

42.8 PRIOR VERSIONS

Unless applicable law requires otherwise, a revised Privacy Policy governs FCGI's processing from its applicable effective date forward.

A revision does not retroactively authorize processing that was unlawful when performed.

FCGI may retain prior versions of this Privacy Policy for legal, regulatory, evidentiary, compliance, archival, or business-record purposes.

42.9 MANDATORY LAW CONTROLS

FCGI INTENDS THIS SECTION TO RESERVE THE BROADEST LAWFUL RIGHT TO MODIFY ITS PRIVACY POLICY AND PRIVACY PRACTICES.

IF APPLICABLE LAW, A BINDING REGULATORY REQUIREMENT, OR AN APPLICABLE PLATFORM REQUIREMENT REQUIRES NOTICE, CONSENT, AUTHORIZATION, AN OPT-OUT RIGHT, OR ANOTHER PROCEDURE THAT CANNOT LAWFULLY BE DISCLAIMED, THAT REQUIREMENT CONTROLS ONLY TO THE EXTENT NECESSARY TO SATISFY THE APPLICABLE REQUIREMENT.

43. THIRD-PARTY WEBSITES AND SERVICES

The Service may contain links to websites, services, applications, promotions, content, or resources operated by third parties.

FCGI does not control the privacy practices of an independent third party merely because FCGI provides a link to the third party.

Users should review the applicable third party’s privacy policy before providing Personal Data directly to that third party.

This provision does not reduce FCGI’s responsibility for third-party processors or SDKs where applicable law makes FCGI responsible for those providers’ processing on FCGI’s behalf.

44. PRIVACY POLICY AND TERMS OF SERVICE

This Privacy Policy governs FCGI’s collection, use, processing, disclosure, retention, protection, and handling of Personal Data.

FCGI’s Terms and Conditions, End User License Agreement, competition rules, promotion rules, school agreements, institutional agreements, sponsorship agreements, and other applicable agreements may separately govern:

access to the Service;
software licensing;
intellectual property;
acceptable use;
cheating;
tampering;
reverse engineering;
decompilation;
data extraction;
scraping;
automation;
bots;
security attacks;
leaderboard manipulation;
achievements;
competitions;
rewards;
promotions;
sponsor rights;
user-generated content;
suspension;
termination;
warranties;
liability;
dispute resolution; and
other contractual matters.

Nothing in the Terms or another agreement eliminates a non-waivable privacy right provided by applicable law.

45. NO TRANSFER OF INTELLECTUAL PROPERTY RIGHTS

Collection, storage, transmission, processing, publication, or display of information through the Service does not transfer ownership of FCGI intellectual property or other protected content to a user, school, sponsor, promoter, partner, service provider, or other person.

Full Color®, Full Color® Solitaire, FCGI products, game systems, software, designs, scoring systems, graphics, content, trademarks, copyrights, databases, game histories, proprietary analytics, and related intellectual property remain subject to the applicable ownership, license, and intellectual-property rights.

Certain content may be owned by David W. Mahon and licensed or otherwise authorized for use by Full Color Games, Inc.

Privacy rights concerning Personal Data do not create a license to copy, reproduce, commercially exploit, scrape, redistribute, sell, broadcast, sublicense, reverse engineer, or otherwise misuse FCGI intellectual property or proprietary systems.

Licensing inquiries may be directed to:

licensing@fullcolorgames.com

46. CONTACTING FCGI

Questions, concerns, requests, or complaints concerning this Privacy Policy or FCGI’s privacy practices may be directed to:

privacy@fullcolorgames.com

Full Color Games, Inc.

5348 Vegas Dr.

Las Vegas, NV 89108

United States

Users should provide sufficient information for FCGI to understand the request.

FCGI may request reasonable verification before responding to a request involving Personal Data.

47. PRIVACY COMPLAINTS

FCGI encourages users to contact FCGI directly with privacy concerns so that FCGI can investigate and respond.

Nothing in this Privacy Policy prevents a person from submitting a complaint to a governmental, regulatory, consumer-protection, or data-protection authority where applicable law provides that right.

Individuals in the European Economic Area, United Kingdom, or another jurisdiction providing a right to complain to a supervisory authority may exercise that right subject to applicable law.

48. GOVERNING PRIVACY RIGHTS

This Privacy Policy is intended to provide global notice concerning FCGI’s Personal Data practices.

Privacy rights may differ by jurisdiction.

Where a provision of this Privacy Policy conflicts with a mandatory privacy right under law applicable to a particular user, the mandatory legal requirement controls to the extent of the conflict.

Nothing in this Privacy Policy is intended to waive a right that applicable law does not permit a user to waive.

49. EFFECTIVE DATE AND SUPERSESSION

This Privacy Policy is effective as of the Effective Date listed at the top of this Privacy Policy.

As of its Effective Date, this Privacy Policy supersedes prior generally applicable FCGI privacy policies with respect to the FCGI Services within its scope, except to the extent a separate legally binding privacy, school, institutional, competition, promotion, data-protection, or other agreement expressly governs particular information or a particular relationship.

This Privacy Policy governs FCGI's processing from its applicable Effective Date forward.

Nothing in this Section retroactively authorizes processing that was unlawful when performed or eliminates a right or obligation that applicable law does not permit FCGI or a user to waive.

50. CONTACT INFORMATION

FULL COLOR GAMES, INC.

Privacy inquiries:

privacy@fullcolorgames.com

Licensing inquiries:

licensing@fullcolorgames.com

Mailing address:

Full Color Games, Inc.

5348 Vegas Dr.

Las Vegas, NV 89108

United States

Website:

www.fullcolorsolitaire.com

END OF GLOBAL PRIVACY POLICY

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