Please read this Privacy Notice and Policy (“Policy”) carefully. It applies to all information
Batcave Digital LLC and its affiliated entities (collectively “Company”, “we”, or “us”) collect
from you through our web sites and game applications (collectively “Services”). Company is a
developer and distributor of digital games via applications available via the app store of Google.
This Policy describes:
• the information we collect, how we collect it, and why;
• how we use and share that information;
• how you can access and update that information;
• the choices you can make about how we collect, use, and share your information; and
• how we protect information.
If you do not want us to collect, use, or share your information in the ways described in
this Policy, you should not access or use the Services. By accessing or using the Services,
you expressly acknowledge and agree to the terms of this Policy, and agree to the
processing of your Personal Information as specified herein.
By using the Services, you acknowledge that we will use your information in the United
States, and any other country where we operate. Please be aware that the privacy laws and
standards in certain countries, including the rights of authorities to access your personal
information, may differ from those that apply in the country in which you reside. We will
transfer personal information only to these countries to which we are permitted by law to
transfer personal information, and we will take steps to ensure that your personal
information continues to enjoy appropriate protections. Please read on to learn more
about how we protect personal information, including when we transfer personal
information outside of the EU.
1. What is Personal Information?
“Personal Information” means information that specifically identifies an individual such as a
name, address, telephone number, mobile number, or e-mail address, or information about an
individual that could be directly linked to such identifying information such as device IP
address and geo-location information (“Device Information”). Personal Information does not
include “Usage Information” (meaning anonymous site usage information such as visit
statistics, page views, device type, etc.), unless such information is connected to your Personal
Under the EU’s General Data Protection Regulation (GDPR), to the extent applicable, personal
data is defined as: “any information relating to an identified or identifiable natural person ('data
subject'); an identifiable natural person is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification number, location data,
an online identifier or to one or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural person.”
2. Information Collected on Our Services
Information You Provide To Us.
You may choose to provide Personal Information through the Services. The Company may
collect Personal Information when you request information from us, contact us, or submit
comments. If you do not want your Personal Information collected in this manner, please do
not submit it.
You may also elect to participate in certain activities on our Services that let you publicly
communicate or share information such as player profiles, message boards, chat or messaging
features, or gifting/invitation-sending features. If you participate in these activities, we may
collect any or all of the information you submit, even if submitted through a player-to-player
We will also collect your Personal Information when you access the Services through a social
networking site, such as Facebook, or through Facebook Connect functionality, including any
or all of the following information: your name; your profile picture; your social network ID
number; your friends’ public profile data on the social networking site; your email address;
your location; your gender; your birthday or age; and any other information that the social
networking site chooses to share with us. If you access the public areas of the Services through
a social networking site or application, we may post your profile information and picture as
allowed by the social networking site.
Information Collected by Automated Means.
Whenever you use the Services, the Company, as well as any third-party advertisers and/or
service providers, may automatically collect Usage Information and Device Information. The
technologies used on the Services to collect Usage Information and Device Information may
include, without limitation, web beacons and cookies. Web beacons (also known as Internet
tags, pixel tags, tracking beacons and clear GIFs) are clear/transparent graphic images placed
on a web page or email which gather Usage Information and Device Information. Cookies are
data files placed on a device when it is used to visit the Services. If you would prefer not to
accept cookies, most browsers will allow you to: (i) change your browser settings to notify you
when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable
existing cookies; or (iii) to set your browser to automatically reject any cookies. However,
please be aware that if you disable or reject cookies, some features on our Services may not
work properly because we may not be able to recognize you, and offers we provide may not be
as relevant to you.
We use tracking technologies to recognize your logged-in state on Services, to understand what
Service features visitors are interested in, to make the Services function for you, and to help
your browsing experience and use of the Services feel more customized. More generally, we
use tracking technologies for the following.
Security and Authentication (Strictly Necessary)
Some cookie and similar technology functions are necessary and vital to ensuring that the
Services work properly for visitors, such as maintaining the security, safety, and integrity of the
Services, authentication and logging into Services (including remembering permissions and
consents you have granted), and ensuring the ability to securely complete transactions.
Account and User Preferences
Some technologies are used to remember your account and preferences over time, such as
remembering your account or keeping yourself logged in when returning to the Services, and
maintaining your choices with respect to Service features, and customizing content based on
how you use the Services.
Some technologies help you to interact with social networks you are signed into while using the
Services, such as sharing content with the social network, logging in with the social network,
and other features you employ with the social network, or that are allowed in the social
preferences with those social networks.
Performance and Analytics
Some technologies help provide performance data on how the Services are functioning in order
to improve the Services, including, for example, data on site and app functionality and speed to
help us optimize the Services, and detect and gather reports on bugs to help make the Services
The Services also employ Google Analytics to help us understand how the Services are used by
visitors. For some of the advertising features listed below, like retargeting, data from Google
Analytics may be combined with our first-party data and third-party cookies (like Google’s
advertising cookies). To see how to opt-out of Google Analytics Advertising Features, see the
Opt-Out section of this policy.
We partner with third-party service providers that may use various tracking technologies to
permit us and them to learn about what ads you see and click when you visit the Services, or to
show you ads on and off Services. These may include things such as:
Frequency capping, which limits the number of times a user’s browser or mobile device
displays the same ad;
Attribution tracking, which estimates what advertising or marketing source brought someone to
the Services, or determines what marketing source led to actions like a visit or a purchase;
Remarketing, which shows relevant ads to an audience based on prior browsing patterns on
Audience targeting, which refers to targeting advertisements to a large audience based on the
audience’s known or inferred demographics; and
Cross-device recognition, which recognizes actions across multiple devices or browsers.
Some third-party service providers may provide information like demographics, cross-device
information, or interest categories from a combination of sources that, while not identifying you
personally, permit us to provide you with more relevant and useful advertising. In some cases,
this information may have non-marketing performance analytics uses as well.
These technologies allow a partner to recognize your computer or mobile device each time you
visit the Services based on data like a cookie, your IP address, or device ID, but do not allow
access to other personal information from us. However, these technologies may allow us or a
third party to recognize you, either from a single device or across devices, over time. These
third parties are required to follow applicable laws, self-regulatory programs, and our data
protection rules where applicable. However, we do not have control over these third parties,
who each have their own privacy policies and privacy practices.
Information We Receive from Third Parties.
We also may supplement and combine the information we collect about you through the
Services with other information we receive from third parties in order to enhance our ability to
serve you, to tailor our content to you, and to market products and services to you. In those
cases, we will apply this Policy to any Personal Information received, unless we have disclosed
3. How We Use Information
When you access or use the Services, we collect, use, share, and otherwise process your
Personal Information as described in this Policy. We will use Personal Information and other
information we collect through the Services:
• to provide the services and information you request;
• to process your transactions through the Services;
• to contact you about your use of the Services;
• to respond to your emails, questions, comments, and complaints, and to otherwise
provide customer service;
• to personalize and improve the Services, and to deliver advertisements, content, or
features that match our users’ interests;
• to monitor and analyze Usage Information and otherwise measure the effectiveness of
• to send you confirmations, updates, security alerts, and support and administrative
messages, to detect and prevent fraud, and to otherwise facilitate your use of, and our
administration and operation of, the Services; and
• to notify you about important changes to our Services.
We rely on a number of legal bases to use your information in these ways. These legal bases
• necessary to perform the contractual obligations in our Terms of Service;
• necessary in order to provide the Services to you;
• you have consented to the processing, which you can revoke at any time;
• necessary to comply with a legal obligation, a court order, or to exercise or defend legal
• necessary for the purposes of our or a third party’s legitimate interests, such as those of
other visitors or our vendors;
• you have made the information public;
• necessary in the public interest; and
• necessary to protect your vital interests, or those of others.
4. What Personal Information do we share with third parties?
We will not share the Personal Information we collect from you through the Services with third
parties, except as described in this Policy or in the Services. We may share non-Personal
Information, such as Usage Information, with third parties. We may share your information
with third parties in the following circumstances:
Third Parties Providing Services on Our Behalf.
We may share your Personal Information with third parties that perform services on our behalf
(or on behalf of our partners), such as companies that host or operate our Services; provide
customer service; manage payments; and provide marketing services to us. Such third parties
are obligated to maintain the confidentiality of your Personal Information, and only use it to
provide services on our behalf as directed by us.
Your Agreement to Have Your Personal Information Shared.
While on our Services, you may have the opportunity to opt-in to receive information and/or
marketing offers from someone else or to otherwise consent to the sharing of your information
with a third party. If you agree to have your Personal Information shared in this way, your
Personal Information may be disclosed to the third party and the Personal Information you
We may also share your Personal Information with our subsidiaries and affiliated entities, and
such entities may use your information in accordance with this Policy. As we continue to
develop our business, we may sell or purchase assets. If another entity acquires us or all or a
portion of our assets, Personal Information and any other information that we have collected
through the Services may be disclosed to such entity as part of the due diligence process, and
will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or
reorganization proceeding is brought by or against us, all such information may be considered
an asset of ours, and as such, may be sold or transferred to third parties. In the event of such a
transfer, the acquiring entity will remain obligated to treat your Personal Information in
We may transfer and disclose information, including your Personal Information, to third parties
to comply with any legal obligation; at the request of governmental authorities conducting an
investigation or otherwise requiring disclosure (including without limitation to meet law
enforcement requirements and for the purposes of national security); to verify or enforce our
Terms of Service; or to otherwise protect the rights, property, safety, or security of us, the
public and/or other users of our Services.
5. How Long We Keep Your Information
The amount of time we will retain your Personal Information depends on why we collected it
and how we use it. We will never retain your Personal Information for longer than we are
allowed under applicable law, and otherwise, will not generally retain your Personal
Information for longer than is necessary to accomplish our business purposes and protect our
6. Your Rights as Data Subject; Your Access and Choices
At any point while we are in possession of or processing your Personal Information, you, the
data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold
• Right of rectification – you have a right to correct data that we hold about you that is
inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about
you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to
restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred
to another organization.
• Right to object – you have the right to object to certain types of processing such as
• Right to object to automated processing, including profiling – you also have the right
to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that we refuse any of your above-specified
requests, we will provide you with a reason as to why. You have the right to complain
as outlined in this Policy.
All of the above requests will be forwarded on should there be a third party involved in the
processing of your Personal Information.
Accessing, Updating, and Transferring Your Information.
If you want to review, change, or transfer the information we maintain about you or have
To manage the information we receive about you from a social networking site, like Facebook,
where you access or use our Services, you will need to follow the instructions at that site for
updating your information and changing your privacy settings. The privacy management tools
for applications on Facebook can be found here.
Stopping Use of Your Information.
additional questions, e-mail us at firstname.lastname@example.org. We will respond to your
request within ten (10) days. Depending on the nature and scope of your request, we may
require that you confirm your identity by providing two of the following documents: birth
passport, driving license, or utility bill showing name and address.
If you no longer want us to make active use of your information, you may send an e-mail to
email@example.com requesting deletion of your information. We will respond to your
request within ten (10) days. Please note that certain records (for example those relating to
customer service matters) will be maintained for legal and accounting purposes. Please also
note that we may not be able delete all content you have posted through the Services (for
example, in public forums), and we may not be able to delete all residual copies of information
in our backup systems.
Most internet browsers allow you to disable or delete cookies and reject placement of new
cookies. Please be aware that certain portions of the Services may not work properly for you,
or provide personalized or customized content, if you take these steps.
You may opt out of Flash Cookie placement at
You can opt out of some third-party advertising programs that use your information. To do so,
please visit the NAI Opt-Out Page: http://www.networkadvertising.org/managing/opt_out.asp.
In order to opt-out of sharing your geolocation and other data with us from your mobile device,
you can visit the “settings” page of your mobile device and review the information sharing
permissions of each application or “app.”
We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral
Advertising (also referred to as “interest-based advertising”) and respects the DAA’s consumer
choice tool for you to opt out of interest-based advertising at https://optout.aboutads.info.
If you do not wish to have your information used for the purpose of serving you interest-based
advertisements, you may decline to receive interest based ads through
TrustE/TrustArc’s preferences manager (or if you are located in the EU click here). Please note
this does not stop you from being served advertisements. You will continue to receive generic
For Google Analytics Advertising Features, you can opt-out through Google Ads Settings, Ad
Settings for mobile apps, or any other available means (for example, the NAI's consumer optout
listed above). Google also provides a Google Analytics opt-out plug-in for the web.
When you install our apps on your mobile device you may receive push notifications from us,
which are messages an app sends you on your mobile device even when the app is not active.
You can turn off push notifications by visiting your mobile device’s “settings” page.
You may opt out of receiving marketing communications from us by sending us an e-mail at
firstname.lastname@example.org, or by following the unsubscribe instructions in the communication
that you receive. Your opt-out request will be processed within ten (10) days of the date we
receive it. Note that if you opt-out of marketing communications, we may still e-mail or
communicate with you if we need to provide you with information about the Services, your
transactions with the Services, or for any other legitimate non-marketing purposes.
When you have opted-in to receiving SMS messages (i.e. text messages) from us as provided in
our Terms of Service, you can opt out of receiving the SMS messages by texting back STOP to
the number we send the text from for that particular SMS message program. When we receive
an opt-out message from you for SMS messages, we may send a message confirming our
receipt of your opt-out.
If you access Services through our mobile applications, you may also control interest-based
advertising on an iOS or Android device by selecting the “Limit Ad Tracking” option in the
privacy section of the Settings App on iOS or via advertising preferences on Android-based
devices (usually in the Google Settings app). This will not prevent you from seeing
advertisements, but will limit the use of device advertising identifiers to personalize ads based
on your interests.
Some web browsers incorporate a "Do Not Track" feature that signals to web sites that you visit
that you do not want to have your online activity tracked. Please note that Company does not
interpret or respond to "Do Not Track" signals.
7. Your California Privacy Rights
If you are a California resident and you decide that you do not want us to share your Personal
Information with third parties for their marketing purposes, please send an e-mail to
email@example.com. In this e-mail, state that you would like the Company not to share
your Personal Information with third parties for their marketing purposes. Your opt-out request
will be processed within thirty (30) days of the date of which we receive it.
opting in to this Policy by means of any mechanism we provide, you consent to the collection,
processing, maintenance, and transfer of such information in and to the United States and other
territories in which the privacy laws may not be equivalent to those in the country where you
reside and/or are a citizen.
We store information about players and visitors to our Services on servers located in the United
States and other countries outside of the EU. Personal Information collected within the EU may
be transferred to, and stored at, a destination outside of the EU. The data we hold may also be
processed by employees operating outside of the EU who work for us or one of our affiliated
entities or vendors. This staff may be engaged in, among other things, (i) the processing of
transactions and your payment details and (ii) the provision of support services. When we transfer
your personal information internationally we will take reasonable steps to ensure that your
personal information is treated securely, lawfully and in the manner we describe here. Please note
that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places
where your information is transferred to or stored, used or processed in, may be different from the
privacy laws applicable to the place where you are resident.
To the extent that we are deemed to transfer Personal Information outside of the EU, we rely
separately, alternatively, and independently on the following legal bases to transfer your
The European Commission has adopted standard contractual clauses (also known as Model
Clauses), which provide safeguards for personal information that is transferred outside of
Europe. We often use these Model Clauses when transferring personal information outside of
Necessary for the performance of the contract between You and Us
We provide voluntary Services; you can choose whether or not you want to use the Services.
However, if you want to use the Services, you need to agree to our Terms of Service, which set
out the contract between us and our Service users. As we operate in countries worldwide
(including in the US) and use technical infrastructure in the US to deliver the Services to you,
in accordance with the contract between us, we need to transfer your personal information to
the US and to other jurisdictions as necessary to provide the Services.
8. Links to Other Sites
The Services may provide links to other web sites that we do not own or operate. We do not
control, recommend, or endorse, and are not responsible for, these websites or their content,
products, services, or privacy practices.
9. How We Protect Personal Information
We maintain certain administrative and technical safeguards to help protect against loss, or
unauthorized access to or disclosure, of your Personal Information. However, no electronic data
transmission or storage of information can be guaranteed to be 100% secure. We cannot ensure
or warrant the security of any information you transmit to us, and your use of the Services is at
your own risk.
10. International Operations; Transfers of Information Outside of EU
The Services are operated in the United States and other countries outside of the EU. Please be
aware that information we collect will be transferred to and processed in the United State and
other countries outside of the EU. By using the Services, providing us with any information, or
The Services are not directed to children under 18. We do not knowingly collect information
from anyone under 18 years of age. If we determine upon collection that a user is under this
age, we will not use or maintain his/her Personal Information.
This Policy may be updated periodically and without prior notice to you, and any changes will
be effective immediately upon the posting of the revised Policy through the Services. However,
we will use your Personal Information in a manner consistent with the Policy in effect at the
time the information was collected, unless you consent to its use in accordance with a new or
different version of the Policy. We will always indicate at the top of this Policy when it was
most recently updated.
14. How to Contact Us
If you have any questions or comments about this Policy, please contact us at