Privacy Policy

Last updated: April 18, 2025

This Privacy Policy outlines our methods and practices regarding the gathering, utilization, and sharing of Your information when You engage with our mobile application Scratch to Riches (the "Service"). It also informs You of Your privacy rights and the legal protections afforded to You.

By engaging with our Service, You consent to our collection and use of Your personal data as described in this Privacy Policy, aimed at enhancing and delivering the Service. This includes showing advertisements through trusted partners, and allowing You to contact our support team via email, processed through Zoho Desk.

Definitions And Interpretation

Interpretation

The terms with capitalized initial letters have specific meanings as defined below. These definitions apply consistently, whether the terms are used in the singular or plural form.

Definitions

For the purposes of this Privacy Policy:

You, Your – means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as You are the individual using the Service.

Company (referred to as either “Bonus Level”, “Bonus Level Ltd.”, "the Company", "We", "Us" or "Our" in this Agreement) refers to BONUS LEVEL LTD. Nikou & Despoinas Pattichi, 37, EVI COURT, 2nd floor, Office 202, 3071, Limassol, Cyprus, email address support@bonuslevel.eu.

For the purpose of the GDPR, the Company is the Data Controller.

Controller (“Data Controller”) – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal data.

Joint Controllers – two or more Controllers jointly determine the purposes and means of processing the same Personal data.

Games – refers exclusively to the mobile game Scratch to Riches, provided to You by the Company through Mobile App or other platforms or Websites.

Mobile App (“Mobile Application”) – the mobile application called Scratch to Riches, available on online platforms, provided by the Company to offer entertainment and in-app advertising.

Website – any Bonus Level website through which We may grant access to Games and/or provide any Service. 

Service – any service We provide to You through the Scratch to Riches Mobile App, our Website, or third-party platforms, including support services and advertising display.

Account – Scratch to Riches does not require the creation of a personal user account. All gameplay and data collection take place without the need for registration.

Personal data is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Service Provider – any natural or legal person who processes the data on behalf of Bonus Level. It refers to third-party companies or individuals employed by Bonus Level to facilitate the Service, to provide the Service on behalf of Bonus Level, to perform services related to the Service or to assist Bonus Level in analyzing how the Service is used.

For the purpose of the GDPR, Service Providers are considered Data Processors.

GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC. The GDPR imposes specific obligations on entities that perform operations on Personal data (whether on their own behalf or on behalf of another entity). It guarantees the exercise of Your data protection rights.

Game Currency – in-game virtual currency used in Scratch to Riches for entertainment purposes only. 

Virtual Goods – in-game virtual items such as game virtual currency, coins etc. 

Personal Data Controllers

The Controller of Your Personal data is Bonus Level Ltd., with its registered office at Nikou & Despoinas Pattichi, 37, EVI COURT, 2nd floor, Office 202, 3071, Limassol, Cyprus, email address support@bonuslevel.eu.

We act as the Data Controller for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws. 

Collecting And Using Your Personal Data

Data Collection During Service Use

We collect only the data that is necessary to operate and improve the mobile game Scratch to Riches, deliver advertising through trusted partners such as Google AdMob, process in-app purchases, and respond to user support requests.

Some of this data is collected automatically through Your interaction with the app. Other data may be provided by You directly (e.g. when contacting support).

We do not require You to create a personal account, and we do not collect Your name or email unless You voluntarily submit it via the support feature.

Cookies, Mobile Identifiers, and Other Similar Technologies

Cookies

We collect Data about Your device and how You use our Games or Services, utilizing cookies, similar technologies, and mobile identifiers. These tools are primarily used to provide You with our Games and Services and to enhance their quality, to tailor recommendations to interests and serve targeted ads.

When You use the Service, Bonus Level along with our service providers and third parties, may deploy cookies on Your device. Cookies are small data files stored on Your device that are used primarily for record-keeping. These cookies may store information that is linked to Your personal data. Additionally, third-party advertisers might utilize cookies and other related technologies on Your device according to their own policies.

For details on how to opt out or disable cookies, please refer to the Your Personal Data Protection Rights section below.

Other Technologies

Alongside cookies, We, our service providers, and third parties, may use various tracking technologies such as (i) web beacons, which help us determine if a specific page has been visited or if an email has been opened; (ii) tracking pixels, which assist us and our advertising partners in recognizing Your devices across different services and devices, enhancing the efficiency of ad campaigns; and (iii) local shared objects, also known as flash cookies, which are instrumental in reducing fraud, storing Your in-game settings, and improving loading times.

For analytics and demographic insights, we employ tools like Facebook Audience Insights, among others.

Types of Personal Data Collected and Processed, the Purposes, and Legal Bases

While using our Mobile App, visiting our Websites, playing our Games, or utilizing other Services We offer, We collect and process only the Personal data necessary to provide You with the Service. The types of information collected may vary based on the activity and the specific Game You play.

Purpose of Data Collection and Processing Data Type Legal Basis for Data Collection and Processing
Identifying if You are a minor or adult to apply the correct data protection measures and comply with legal processing requirements. Age Classification (21 or older) This processing is crucial for adherence to legal obligations, as specified in Article 6(1)(c) of the GDPR. Regulation (EU) 2016/679 by the European Parliament and of the Council from 27 April 2016 focuses on the protection of natural persons regarding personal data processing and the free movement of such data.
Providing access to the game and its core functionality

Information about Your use of Our Games or Services, such as Your game progress, scores, session durations and times, achievements, in-app purchases, and interactions with game features and other players.

Crash information including crash logs, stack traces, and device specifications.

Necessity for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract (Article 6(1)(b) of GDPR) 
Analyzing Your activity within our Games or Services to optimize performance, tailor gameplay and offers to Your preferences, conduct marketing activities, deliver personalized ads, and detect fraud.

IP address or other location data,

language,

time zone,

type of Your computer or mobile device,

platform type (like Apple iOS or Android),

operating system version,

network information, like mobile carrier,

Mobile device’s identifiers, like Your Device’s Unique Identifier (UDID), Your MAC Address, Apple Identifier For Advertising (IDFA), Android Advertising ID (AAID), App Set ID and/or Google Advertising ID (GAID), and/or International Mobile Equipment Identity (IMEI);

browser type and language,

referring and exit pages and URLs,

the number of clicks on a page or feature,

domain names,

landing pages,

pages viewed and the order of those pages,

the amount of time spent on particular pages,

product preferences, privacy preferences or other users’ choices.

The status of the game and the specific dates and times of Your activities within the game.

Data about Your use of Our Games or Services, such as Your game progress, scores, session durations and times, achievements, in-app purchases, and interactions with game features and other players.

Crash information including crash logs, stack traces, and device specifications.

We might connect this information with Your social network ID and/or Game Player  ID.

Your consent (Article 6(1)(a) of GDPR)  

Necessity for the performance of a contract (Article 6(1)(b) of GDPR).

The Company's legitimate interest (Article 6(1)(f) of GDPR) involves analyzing Our players’ behavior to improve and optimize our Services, including offering Service that is free to play.

Fulfilling a submitted purchase order and providing the Virtual Goods

User ID

Transaction Information

Necessity for the performance of a contract (Article 6(1)(b) of GDPR)
Sending direct marketing communications or conducting satisfaction surveys to maintain our relationship with You. We may reach out to You with direct marketing messages via Mobile App, or push notifications. Device push tokens Legitimate interest pursued by Bonus Level (Article 6(1)(f) of GDPR) consisting of conducting marketing activities and satisfaction surveys    

Managing our social media profiles to keep You updated on our activities, games, and services, as well as to promote various events, services, and products.

When You visit our social media profiles (such as Facebook, YouTube, Instagram), We use Your personal data solely for the purpose of maintaining and managing these profiles.

Personal data You share publicly on the respective social media platform The legitimate interest pursued by the Company (Article 6(1)(f) of GDPR) involves promoting its own brand.
Managing complaints

Your name

Email address

User ID

Subject of the complaint 

Content of the complaint

Necessity for the performance of a contract (Article 6(1)(b) of GDPR)  
Managing data subject requests

Your name

Email address

User ID

Subject of the request 

Content of the request

Legal duty (Article 6(1)(c) of GDPR)  
Managing other requests and applications  

Your name

Email address

User ID

Subject of the request 

Content of the request

The legitimate interest pursued by Bonus Level (Article 6(1)(f) of GDPR) includes responding to inquiries related to its business activities. For data provided optionally, the legal basis for processing is consent (Article 6(1)(a) of GDPR).
Improving Services quality

Data about Your use of Our Games or Services, such as Your game progress, scores, session durations and times, achievements, in-app purchases, and interactions with game features and other players.

Data regarding Your activities on the Mobile App and Websites

Interactions with our support team, along with any extra Data shared during those communications, to provide assistance and improve our Games and Services.

The Bonus Level's legitimate interest (Article 6(1)(f) of GDPR) involves analyzing Your activities on the Mobile Apps and Websites to enhance the functionalities You use.

Personal Data Retention

We retain Your Personal data only for as long as necessary for the purposes outlined in this Privacy Policy. Your data is used to fulfill legal obligations, resolve disputes, and enforce agreements and policies.

Usage data is kept for internal analysis and is generally retained briefly unless it is used to enhance security or functionality, or if We are legally required to retain it longer.

The duration of data processing may be extended if necessary to establish, assert, or defend against legal claims. After the end of the processing period, the data is irreversibly deleted or anonymized.

We process Your personal data for the following purposes:

Transfer of Personal Data

Data Transfer for EU Residents

If You are a resident of the EU, please note that when You use our Games or Services, Your Personal data may be processed outside of European countries, such as in the United States, and possibly other countries. When We transfer, store, and use Personal data collected in European countries outside of these regions, We comply with Our legal obligations and ensure that Your Personal data is subject to appropriate safeguards (such as encrypted communication or the use of Standard Contractual Clauses) or transferred to "approved" territories with adequate protection equivalent to EU standards. We are responsible for Your Personal data and strive to protect it diligently.

International Data Transfer

We may transfer Your Personal data to third parties located in various countries. When transferring Your personal data internationally, We take reasonable steps to ensure that Your data is treated securely and in compliance with legal requirements.

Handling Concerns and Complaints

If You have any questions, concerns, or complaints regarding Bonus Level's handling of personal data or compliance with safeguards related to transfers outside European countries, You can contact our Data Protection Officer (see contact details in section “Contact Us”). If Your complaint is not resolved through these channels, an additional binding arbitration option may be available to You.

Personal Data Sharing

We may share Your Personal data with third parties or allow third parties to collect this information from our Games or Services as described below.

We ensure that any third party with whom We share Your Personal data provides the same level of protection as outlined in this Privacy Policy.

 

Security Measures

We share Your Personal data if necessary for safety, security, or compliance with the law. Your Personal data and the contents of all Your online communications in Our Games and between You and Bonus Level may be accessed and monitored as needed to provide our Games and Services and may be disclosed:

Service Providers and Other Third Parties

In connection with providing Games and Services, Your Personal data may be disclosed to external entities such as, service providers and vendors responsible for IT system maintenance, payment operators, and entities related to Bonus Level.

With Your consent, We might also use and share Your Personal data with some trusted advertising network companies to tailor advertisements to Your interests. The list of such advertising network companies and their privacy policies can be found here and may be updated from time to time.

Additionally, We may share Your personal data with other third parties or allow them to collect Your information from our games or services in ways not specifically described in this Privacy Policy if We have Your consent.

Only designated Service Providers have access to Your Personal Data, strictly for carrying out their duties. We share Your details with specified categories of recipients under GDPR's legal frameworks detailed in Sections 6(1)(b), 6(1)(c), and 6(1)(f).

Main Service Features

We may use third-party service providers to offer main and additional features of our service.

Zoho Desk

Provided by Zoho Corporation Pvt. Ltd., We use Zoho Desk for customer support. For details, see Zoho Desk's Privacy Policy: https://www.zoho.com/privacy.html.

Advertising

We work with trusted advertising network companies, both directly and indirectly, which may receive and process Your personal data according to their own policies. We recommend reviewing the privacy policies of our partners to understand how they handle Your data. With Your consent under Section 6(1)(a) of the GDPR, We share Your advertising ID with these companies to deliver personalized behavioral advertisements within the app.

We also use service providers to display ads to help support and maintain our service. Note that Bonus Level may not work directly with or share data with all the companies listed below. We periodically update this list as We establish new partnerships with companies dedicated to protecting Your personal data.

AdMob by Google

AdMob by Google is provided by Google Ireland Limited.

Opt-Out: You can opt out of AdMob by following the instructions provided by Google: https://support.google.com/ads/answer/2662922?hl=en.

More Information: To learn how Google uses the collected data, visit: https://policies.google.com/technologies/partner-sites or view the Google Privacy Policy.

Liftoff (formerly Vungle)

Liftoff is provided by Liftoff Mobile, Inc.

Opt-Out: Opt-Out: You can opt out of targeted advertising from Liftoff by following the instructions provided on their Opt out page.

More Information: For additional details, please review the Liftoff Privacy Policy: https://liftoff.io/privacy-policy/.

Facebook Audience Network

Facebook Audience Network is provided by Facebook.

Opt-Out: You can opt out of Facebook Audience Network by following the instructions on their Privacy Policy page: https://www.facebook.com/about/privacy/.

More Information: For additional information, see the Facebook Privacy Policy: https://www.facebook.com/about/privacy/.

Chartboost

Chartboost is provided by Chartboost, Inc.

Opt-Out: You can opt out of Chartboost by following the instructions on their Privacy Policy page: https://answers.chartboost.com/hc/en-us/articles/200780269.

More Information: For more details, visit the Chartboost Privacy Policy: https://answers.chartboost.com/hc/en-us/articles/200780269.

Unity Ads

Unity Ads is provided by Unity Technologies.

Opt-Out: You may opt out of personalized ads served by Unity by following the instructions provided in Unity's Privacy Policy. Typically, this involves adjusting your device-level privacy and advertising preferences (for example, selecting "Limit Ad Tracking" on iOS devices or opting out of "Interest-Based Ads" on Android devices).

More Information: For additional details, please review the Unity Privacy Policy: https://unity3d.com/legal/privacy-policy.

The use of the disclosed information by these recipients will not be covered by this Privacy Policy. If You have any questions regarding how these third parties process Your data, You should review their respective privacy policies.

 

Behavioral Remarketing

The Company uses remarketing services to advertise on third-party websites to You after You visit Our Service. We and Our third-party vendors use cookies to inform, optimize, and serve ads based on Your past visits to Our Service.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

Opt-Out: You can opt out of Google Analytics for Display Advertising and customize Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

More Information: For more details on Google's privacy practices, visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Facebook

Facebook remarketing service is provided by Facebook Inc.

Interest-Based Advertising: Learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.

Opt-Out: To opt out of Facebook's interest-based ads, follow these instructions: https://www.facebook.com/help/568137493302217.

Self-Regulatory Principles: Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt out from Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada: http://Youradchoices.ca, or the European Interactive Digital Advertising Alliance in Europe: http://www.Youronlinechoices.eu/, or by using Your mobile device settings.

More Information: For more details on Facebook's privacy practices, visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation .

Payments

We may offer paid products and/or services within the Service. In such cases, We may use third-party services for payment processing (e.g., payment processors).

We do not store or collect Your payment card details. This information is provided directly to our third-party payment processors, whose use of Your personal information is governed by their Privacy Policy.

Apple Store In-App Payments

Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/.

Google Play In-App Payments

Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/.

Microsoft Store In-App Payments

Their Privacy Policy can be viewed at https://privacy.microsoft.com/privacystatement.

Your Personal Data Protection Rights

The Company is committed to respecting the confidentiality of Your Personal Data and ensuring You can exercise Your rights. If You are within the EU, You have the following rights under this Privacy Policy and by law:

You have the right to know what categories of Your Personal Data We collect and who it is shared with.

Right to Access: You can request access to Your Personal Data. You can view, update, or request deletion of Your Personal Data directly within Your account settings under “Support” section. If You are unable to perform these actions Yourself, please contact Us for assistance. This right also allows You to receive a copy of the Personal Data We hold about You.

Right to Correction: You have the right to request correction of any incomplete or inaccurate Personal Data We hold about You.

Right to Object: You can object to the processing of Your Personal Data if We are relying on a legitimate interest as the legal basis for Our processing, and there is something about Your particular situation that makes You want to object. You also have the right to object if We are processing Your Personal Data for direct marketing purposes.

Right to Data Portability: You can request the transfer of Your Personal Data to You or a third party in a structured, commonly used, machine-readable format. This right only applies to automated information You initially provided consent for Us to use or where We used the information to perform a contract with You.

Right to Withdraw Consent: You can withdraw Your consent to use Your Personal Data at any time. To withdraw Your consent, open the application’s Main Menu and select the Withdraw Consent option under the “Support”. Please note that if You withdraw Your consent, We may not be able to provide You with access to the Service.

Right to Erasure: You can request the deletion or removal of Your Personal Data when there is no good reason for Us to continue processing it.

Delete Your Account

While Scratch to Riches does not create a registered user account, You still have the right to request the deletion of all Personal Data associated with Your gameplay or device.

To request data deletion, please send an email to privacy@bonuslevel.eu. Include the following in Your email with the subject line: “Delete My Data – Scratch to Riches”:

You can also request deletion from within the app, by navigating to the Support section and choosing the option “Request Data Deletion”, if available on your version.

Providing this information helps us process your request quickly and accurately. We will start the deletion process after verifying your details and may contact you for additional details. Once complete, all game progress and virtual items will be permanently removed and cannot be recovered. No refunds or compensation will be provided for unused virtual items.

Managing Data Collection

You can manage all aspects of data collection and usage from Your device or third-party applications by visiting the "Settings" and following the instructions of such applications, mobile devices, or web browsers to check access permissions.

Opt-Out of Third-Party Personalized Advertisements

For more information about personalized advertising and how to opt-out, You can visit the following websites:

These opt-out tools are managed by third parties, not by Us. We do not control these tools or the options provided by advertisers through them.

To opt-out of personalized in-app advertisements on Your mobile device, adjust the ad tracking settings in Your device's settings. You can also reset the “Advertising Identifier” (such as IDFA) from Your device’s settings, which will stop the use of existing behavioral data linked to the previous identifier.

Depending on Your platform provider (like Apple or Google), You might be able to download apps such as the Digital Advertising Alliance’s “AppChoices” app, which gives You control over the collection and use of cross-app data for tailored advertising. Similar to the web opt-out tools, these mobile tools are provided by third parties and not controlled by Us.

Please note that even if You opt out of personalized advertising, You may still receive non-personalized ads from us and third parties within our Games.

Opt-Out of Cookie Tracking

You can configure Your web browser to alert You when cookies are being placed on Your device or to restrict the types of cookies allowed. Flash cookies function differently from browser cookies, and standard browser tools may not remove them. To manage flash cookies, visit the Adobe website and adjust Your settings at the Global Privacy Settings Panel.

Please note, disabling cookies might affect the functionality and features of our Service, as cookies are essential for providing the Service.

On our websites that utilize cookies, You can also set Your preferences by using the cookie banner or clicking on the "Cookies Settings" link.

Do Not Track

Please be aware that we currently do not respond to Do Not Track signals, regardless of whether the signal is received from a computer or a mobile device.

Exercising Your Data Protection Rights

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond as soon as possible.

You may contact us in the following manner:

You also have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority.

Children's Privacy

Our Service is not aimed at individuals under the age legally defined for consent without parental approval in the jurisdiction of the user. We do not deliberately gather personal information from minors under this legal age threshold. If You are a parent or guardian and discover that Your child has provided us with personal information, please contact us. Upon learning We have inadvertently collected personal information from a minor without appropriate consent, We will take steps to delete such data from our servers.

Additionally, for users aged 21+, We may restrict the collection, usage, and retention of their information, potentially affecting the availability of certain service features.

Links to Other Websites and Services

Our Service may feature links to external sites not operated by us. Clicking on a third-party link will direct You to that site. We strongly advise reviewing the Privacy Policy of each site You visit. We do not control and are not liable for the content, privacy policies, or practices of any third-party sites or services.

Data Security

We store Personal Data on secure servers  and comply with international security standards. All Personal Data is treated as confidential by those with access, and We limit access to only those who need it. Regular audits and internal controls ensure our measures comply with international security standards and internal procedures.

Protecting Your Personal Data is a priority for us, but no method of digital transmission or storage is completely secure. Despite our efforts to use industry-standard measures, We cannot guarantee absolute security.

Contact Us

We have a Data Protection Officer (the “DPO”), who is the person at Bonus Level Ltd. responsible for all matters related to data protection and privacy matters. The DPO is the designated contact for data protection issues for Bonus Level Ltd. You can reach Bonus Level’s DPO at the following address: 

Data Protection Officer, BONUS LEVEL LTD., Nikou & Despoinas Pattichi, 37, EVI COURT, 2nd floor, Office 202, 3071, Limassol, Cyprus;

Email: privacy@bonuslevel.eu

Please be sure to include Your name or Your User ID or address and email address in any correspondence to us so that We can respond to Your inquiry in a timely manner. 

U.S. RESIDENTS SUPPLEMENT

While We treat all our users equally, this section offers additional insights into how We handle personal information for players residing in the United States. Terms used here have the same meanings as elsewhere in this policy, and "You" refers to both players and visitors to our Websites, Games or other Services. 

Our Services might gather details that identify, relate to, describe, reference, are reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific consumer, household, or device (“personal information”) as outlined below.

Personal information does not include publicly available information or deidentified or aggregated consumer information.

We DO NOT (i) sell Your personal information; (ii) knowingly collect, sell, or share personal information of users under 13 years of age; (iii) collect, sell, disclose, or share sensitive personal information. By sensitive personal information, We mean data on race or ethnic origin, religious beliefs, genetic data, biometric data, health data, sexual orientation, philosophical beliefs, the contents of a consumer’s mail, email, text messages that are not directed to us, and personal data from a known child under 13 years of age.

Categories of Personal Information Collected

The following categories of Personal Information We collected within the last twelve (12) months, along with the sources of collection and the business purposes for collection, are detailed in the list below.

Category of Personal Information Categories of Sources
Identifiers, for example: online or advertising identifier (ex. device numbers, ADFA, GAAID etc.), IP address, device or WiFi location.
  • Players
  • Players' Devices
  • Service Providers including Internet Service Providers, Data Analytics Providers, Advertising Networks, Operating Systems and Platforms
  • Social Networks
California Customer Records(Cal. Civ. Code 1798.80(e)) such as address, name.
  • Players
  • Service Providers
  • Social Networks
Protected Classification Characteristics, such as age and gender.
  • Players
  • Service Providers
  • Social Networks
Commercial Information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Players
  • Service Providers including Data Analytics Providers, Operating Systems and Platforms
  • Social Networks
Internet/Network Information, such as website or application or advertisement browsing history, information regarding a consumer’s interaction with an internet website, application, or advertisement.
  • Players
  • Players' Devices
  • Service Providers including Internet Service Providers, Data Analytics Providers, Advertising Networks, Operating Systems and Platforms
Geolocation Data, IP address, device shared location, and Wi-Fi connection location.
  • Players
  • Players' Devices
  • Service Providers including Internet Service Providers, Data Analytics Providers, Advertising Networks, Operating Systems and Platforms
Inferences such as derivation of information, data, assumptions, or conclusions from any of the above categories of personal information..
  • Players
  • Players' Devices
  • Service Providers including Internet Service Providers, Data Analytics Providers, Advertising Networks, Operating Systems and Platforms
  • Social Networks

Business Purposes 

We may use and/or disclose the Personal Information We collect for one or more of the following business or commercial purposes:

Disclosure of Personal Information 

In the last twelve (12) months, We have disclosed the following categories of Personal Information: Identifiers, California Customer Records (Cal. Civ. Code 1798.80(e)), Protected Classification Characteristics, Commercial Information, Internet/Network Information, Geolocation Data, and Inferences.

As outlined in the Privacy Policy, We share Personal Information with various recipients for business and commercial purposes. Besides the categories of recipients identified in the Privacy Policy, We disclose Personal Information to, or grant access to Personal Information by, the following categories of recipients:

We may also share Personal Information with Your social network friends, other users, and successor organizations in the event of Bonus Level’s sale, merger, acquisition, etc.

Bonus Level does not "sell" Personal Information about our players in the conventional sense. However, We may permit certain third-party advertising partners to gather information about consumers via our games and website. This is done to provide more relevant ads, measure ad campaign performance, conduct analytics, and detect and report ad fraud. If this practice could be construed as a "sale" under the CCPA, please refer to our Opt-Out section below for more details (Right to Opt-Out of Sale of Personal Information – Do Not Sell My Info).

Online Advertising

Below are the categories of Personal Information We may sell for business purposes, including those potentially sold in the past twelve (12) months.

When serving You personalized video ads, We may sell identifiers such as resettable identifiers provided by Your mobile device’s operating system to ad networks, social media companies, and other third-party businesses in the ad ecosystem. Common resettable advertising IDs include GAID (Android) and IDFA (Apple), which are considered Personal Information under the CCPA. These third parties may use Your Personal Information:

These third parties may use this Personal Information for their own commercial purposes per their own privacy policies, which might include sharing this information with additional third parties, including other advertising networks.

Financial Incentives

In certain financial incentives offered on select Games, We may provide You with Virtual Currency or other Virtual items across our various Games. These items and currency are virtual, hold no monetary or cash value, and cannot be used outside of the respective Game. For more information, please refer to our Terms of Service.

Financial Incentive Categories of Personal Information Collected How to Opt-In to the Financial Incentive
In-game ads Identifiers, Internet or other electronic network activity information, Commercial information, Location Data, Inferences drawn Watch in-game video ads that may be presented to You
In-game personalized ads Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn  Consent to be served with ads that are tailored to Your personal information and to sharing Your personal information with ad networks, social media companies and other third-party businesses
Reviews about the game Identifiers, location data, inferences drawn Follow the instructions that may be presented to You to submit a review about the game, or rate the game, in an application store such as Google Play.

You have the right to opt-out of the financial incentive at any time. For instance, You can decide not to watch in-game advertisements. Additionally, You may submit a consumer request as outlined below.

Your Rights and Choices  

Right to Know

You have the right to request disclosure of specific information regarding our collection and use of Your Personal Information over the past twelve (12) months. Once We receive and verify Your consumer request, We will provide You with the following details:

Right to Deletion

Upon receiving a verifiable request from You, We will:

However, please be aware that We may not be able to delete Your Personal Information if it is necessary to:

Right to Opt-Out of Sale of Personal Information – Do Not Sell My Info

You have the right to opt-out of the sale of Your Personal Information. As previously mentioned, We do not "sell" Personal Information about our players in the traditional sense. However, since some practices may be interpreted as a "sale" under the CCPA, You have the rights described below.

To exercise Your right to opt-out, please submit a request by contacting us at privacy@bonuslevel.eu.

If You decide to opt-out, You can change Your mind and revoke Your request at any time by contacting us at privacy@bonuslevel.eu .

If You do not wish to receive interest-based in-application advertisements on Your mobile device, You can adjust the ad tracking settings on Your device (such as enabling “Limit Ad Tracking”). Additionally, You can reset the “Advertising Identifier” (such as an IDFA) from Your mobile device’s settings, which will prevent the continued use of existing behavioral data linked to Your previous “Advertising Identifier.” For instructions on limiting ad tracking on iOS devices, follow the link to Limit Ad Tracking. To opt out of personalized ads on Android devices, follow the link to Opt-out of Personalized Ads.

To prevent third parties from delivering personalized web and mobile web advertising, You may also visit the opt-out tools provided by the Network Advertising Alliance and the Digital Advertising Alliance, or download apps like the Digital Advertising Alliance’s “AppChoices” app, which offer controls regarding the collection and use of cross-app data for behavioral advertising.

These opt-out tools are provided by third parties, not Bonus Level. We do not control or manage these tools or the options that advertisers and others offer through them.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

If You choose to exercise any of Your rights, We will not treat You any differently. This means we cannot deny goods or services to You, charge different prices or rates, provide a different level or quality of goods or services, or suggest that You will receive different treatment based on Your exercise of privacy rights.

Right to Designate an Authorized Agent to Submit Requests on Your Behalf

You may be allowed to use an authorized agent to submit requests on Your behalf, if You provide sufficient information to show that the requestor is an authorized agent with written permission to act on Your behalf and You verify Your identity with us.

Shine the Light

You have the right to request information once per calendar year regarding our disclosures of specific categories of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the methods described below.

How to Exercise Your Rights

You may submit a verifiable consumer request to exercise Your right to know and right to deletion by:

The verifiable consumer request must:

We will verify Your request by matching identifying information You provide with the Personal Information We already maintain. We may use existing account authentication methods if applicable. We take all reasonable precautions to verify Your identity. Requests are evaluated based on the individual and information category. We cannot respond to Your request if We cannot verify Your identity or authority. No account creation is required to make a verifiable consumer request. Some requests may require additional Personal Information to verify Your identity. Verification may be done by email or other methods.

We will confirm receipt of Your request within ten (10) business days and explain how We will process it. We aim to respond within forty-five (45) calendar days. If more time is needed, We will inform You of the reason and extension period. Disclosures will cover the twelve (12) months preceding the request

Minors Under Age 16

As described in our Privacy Policy, we do not knowingly collect or share personal data about children.

Changes to this Privacy Policy

We may periodically update our Privacy Policy. We will notify You of changes by updating the date at the top of this policy. For significant changes, We will provide specific notice or obtain Your renewed consent as required. We encourage You to review our Privacy Policy regularly. Changes become effective when posted on this page.

Privacy Policy Terms of Service Do Not Sell My Personal Information
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