April 10, 2019

**Privacy Policy **

**of **

Dusk Ltd.


Dusk Ltd. and its subsidiaries, affiliates, agents, and personnel (“we” or “us”) are fully committed to upholding and protecting the privacy of our loyal customers. Our ultimate goal is to unite people from around the world and bring enjoyment into your home. In our efforts to deliver an entertaining and rewarding experience through our products, we occasionally may need to obtain certain personal information from our customers. However, we do not want to do anything that may jeopardize your safety, comfort, integrity, or dignity.

This Privacy Policy (this “Policy”) is intended to tell you what information we might collect, how we use that information, how we secure it, whether we share it, and your rights related to the same. Please note that when you use our websites, games, game engines, and applications (collectively, our “Products”), you agree to our collection, use, disclosure, and transfer of information as described in this Policy, so please review it carefully. Hopefully, after reading this Policy closely, you will feel confident in our management of your sensitive information and ability to provide an enjoyable experience without requiring you to unreasonably compromise your inherent right to privacy.

Information We Collect and How We Use It

In order to optimize performance of our Products and your experience using the same, we may ask that you provide us with certain personally identifiable information, including but not limited to name, e-mail address, Internet Protocol Address (“IP address”), device name, operating system version, time and duration of use, location, and other information relating to an identified or identifiable natural person. We may also record and publish publicly certain in-game information, such as your username, awards, number of kills, deaths, and significant in-game achievements. We may record and review conversations with customer support representatives and analyze any feedback provided to us through voluntary customer surveys or reviews provided on iOS and Android app stores. Typically, we collect this information when you first install our Products, create an account, play the game, or interact directly with us. As you use our Products, we may occasionally utilize a third-party service provider to collect and analyze certain usage data. If we do, this data will be completely anonymous and will not be associated with you individually.

We only collect such information when we have a legitimate basis or need, such as preparing individualized and private accounts through which you can access our Products, communicating with you, providing personalized support, identifying and repairing bugs, addressing game performance, performing internal analytics, matching users for battles or in-time gameplay, optimizing the game to your device specifications, preventing abuse or misuse, implementing future upgrades, providing important updates about us or our Products, allowing access to premium purchases features, and complying with our legal and ethical obligations.

We retain and use the information we request in accordance with the terms of this Policy, and we may occasionally ask for your consent for certain uses of your personal information such as linking your contacts for a shared experience among friends. You will always have the opportunity to withdraw your consent, opt-out, or unsubscribe from certain marketing uses by contacting us using the information below. We will retain your personal information for as long as you, to the extent of our knowledge, are a user of our Products, subject to erasure as provided in this Policy.

At no point should you provide us with social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership, unless such disclosure is required by law. If you voluntarily send or disclose any sensitive personal data to us at any time, you consent to our processing and use of such sensitive personal data in accordance with this Policy.

Duration of Retention

We will retain the information collected in connection with our Products for as long as required to meet the need for which such information was originally collected, unless (a) otherwise required by law; (b) we receive a valid request for erasure; or (c) another legitimate need arises.


Through our internal analytics processes, we may occasionally rely on the use of “cookies,” or small amounts of information generated by a website and commonly used as anonymous unique identifiers. They do not identify any individual user, necessarily. This information may include your IP address, geographic location, operating system, date and time of visit, and Products downloaded or purchased. You can clear your cookies at any time through your web browser’s settings menu.

We currently do not use these cookies explicitly. However, we and our Products may use third-party analytics, code, libraries, and services that use cookies to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. Additionally, there are a number of products and services that may block or automatically decline the collection of cookies from us and other parties.

Third-Party Service Providers

We may employ third-party companies and individuals to facilitate the use and implementation of our Products, provide the Products on our behalf, perform Product-related services, assist us in analyzing how our Products are used, prevent fraud, or provide certain marketing services. These third parties may provide their own advertisements viewable through our Products, and may have access to your information in order to fulfill these endeavors or provide targeted advertising. Such usage of third-parties, particularly for advertising purposes, are necessary to allow us to continue offering our Products free of charge. We also utilize third parties to facilitate optional in-game purchases. Because of this, we do not collect or have access to any of your financial information.

It is important to note that all of our third-party service providers are obligated not to disclose or use your information for any purpose other than as specifically instructed, and will provide the same or equal protection of your data as stated in this Policy. If you would like to review the privacy policy of any of our third-party service providers, please send us a request using the contact information below detailing what feature you are inquiring about (e.g., payment collection, analytics, marketing, etc.) and we will be happy to direct you to those policies.

Social Media and Links to Other Sites

Our Products may contain links to other sites. You may also have the opportunity to connect to certain social networking sites when you use our Products, if you so choose. Please note that these external sites are not operated by us, so we strongly advise you to review the privacy policies of these websites. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

We may also occasionally run competitions advertised on, or connected directly with, social networking sites. Your involvement in these competitions may require contact through such social media sites, which you are free to reject or block as you see fit.

Transfer; Legal or Consented Disclosures

We transfer the data we collect to servers in the United States. Upon your consent and to the extent legal and reasonably practical, we may also transfer data you provided personally. We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) upon a good-faith belief that such disclosure is necessary to comply with law; (d) under unusual, extraordinary, or emergency circumstances to protect the safety of the public or users of our Products to enforce any of our terms and conditions or policies; or (e) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data to will not be permitted to process your personal data other than as described in this Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Access, Removal, Erasure, and Restriction

You have the explicit right to access your own information, and can request from us a list of your personal data that we process or copies of your personal data, in each case to the extent required and permitted by law.

Each user also has the right to be removed from our catalogs and continue their life anonymously. You have the right to review the data we collect and influence the way in which we use it by contacting us as set forth below. To the extent practicable, you can be forgotten entirely. We will erase all personal data collected if it is no longer needed to serve the purposes for which it was originally collected. We will also erase personal data if the processing was based on consent that you have since withdrawn or restricted.

If you reside in the European Union or United Kingdom, the General Data Protection Regulation (“GDPR”) or U.K. Data Protection Act 2018 provide you with the explicit right to request access to, and correction, rectification, or erasure of, your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority.

You also have several options for restricting what information is automatically transmitted to us, third-party service providers, and similar companies. For example, you can reset your IDFV (device identifier for vendors), install certain software, or utilize virtual private networks. We cannot recommend any specific products or services, and strongly encourage you to conduct the appropriate research before implementing any of these automatic data-transfer restrictions.

For more information about these rights, please visit the European Commission’s “My Rights” page relating to GDPR, which can be displayed in a number of languages. If you reside outside of the European Union and U.K., you may have similar rights under your local laws.

Whether you live in the European Union, United Kingdom, or otherwise believe you have a right to restriction of processing or a right to object to processing under your local laws, and you wish to request access to, or rectification, portability, or erasure of, your personal data, to delete your account, exercise your right to restriction or processing of personal data, or to object to processing, please contact us at the information provided below.

Please note that if your data is removed from our servers, you will lose all of your progress in our games, including access to in-game purchases you may have made.

Security Disclaimer

While we are committed to upholding your privacy, protecting your personal information, and maintaining your trust, please remember that no method of transmission or electronic storage is entirely secure and reliable. As such, we cannot guarantee absolute security, but will provide diligent efforts to ensure your information is as secure as reasonably practical and have already taken technical and organizational efforts to protect your information from loss, misuse, or other unlawful access.

Changes to This Policy

We may update our Policy from time to time as we add new Products, improve our current offerings, as we grow and evolve, and as technologies and laws change. You are advised to review this Policy periodically for any changes. We will notify you of any changes if the same are material and, where required by law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on our webpage or in our Products that link to this Policy. Any change or update will be effective immediately upon posting the revised Policy.


If you disagree with any portion of this Policy, or do not consent to the collection or use of your data as provided herein, we recommend that you please refrain from using our Products. You may contact us for clarification, provided that such contact will be subject to the collection and retention provisions provided herein.

Contact Us

If you have any questions or concerns about this Policy, do not hesitate to contact us at privacy (at) dusk.games