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Privacy Policy

Effective July 20, 2012

Welcome to

This Privacy Policy explains how Spina Technology USA, a Delaware LLC  (“” or “we”), collects, uses and discloses your personal and non-personal information when you access and use any of our games, content, applications, activities, purchases and other services (the “Services”).  The Services may be made available through our website or accessed through a third party social networking website (this “Site”), or as a game application (“Mobile Game App”) on your mobile device.

Please read this Privacy Policy carefully which is incorporated and made part of our Terms of Use Agreement.  If you have any questions, feel free to contact us.  By accessing and using the Services, you acknowledge that you have read, understand and agree to be legally bound by this Privacy Policy, and consent to our collection, storage, use and sharing of your personal information, including the transfer of this information outside the State of California and/or the United States for storage, processing and use by

Children Under Age 13

The Services are offered and made available only to users 13 years of age or older.  YOU MUST BE 13 YEARS OF AGE OR OLDER TO USE THE SERVICES.  By accessing and using the Services, you represent that you are 13 years old or older; and if you are between the ages of 13 and 18, you represent that your parent or legal guardian has reviewed and agreed to the Terms of Use Agreement, including this Privacy Policy.

You may be required to open a user account directly with by completing the registration process and providing true, accurate, current and complete information about yourself. does not knowingly solicit any personal information (including personally identifiable information) from children under the age of 13.  If you are under age 13, please do not attempt to register or send any information about yourself, including your name, address, telephone number, or email address.  No one under age 13 may provide any personal information to us through this Site or the Mobile Game App.  If we determine, in our sole discretion, that a person is under the age of 13, based on the information provided during the registration process, that person will not be permitted to register.

This Site or the Mobile Game App may include hyperlinks to websites operated by third parties, including advertisers, sponsors, and other content providers that require registration. Any website links are provided to you as a convenience only.  These websites may collect data or solicit personal information from children under the age of 13 to register for features in accordance with their own privacy policies. We do not control these websites and we are not responsible for their privacy policies, or for the collection, use or disclosure of any information those sites may collect.  For more information, please review the privacy policies of each respective third party website.

Children Between Ages of 13 and 18

If you are between ages of 13 and 18, you represent that your parent or legal guardian has reviewed and agreed to the Terms of Use Agreement, including this Privacy Policy, and has given permission before you provide any information about yourself.  Parents or legal guardians may delete their child’s previous registration as a player at any time by contacting us.  Information collected is secured in a manner described in this Privacy Policy.  If for any reason you are concerned that your child’s personal information maintained by us is incorrect or incomplete, if you would like to have your child’s personal information deleted from our records, or if you want to discontinue further collection or use of your child’s personal information, please contact us.  We will be happy to review, update or remove your child’s information.

Information We Collect

There are a variety of ways in which you as a visitor accessing and using any Services may provide us with your personal information (including personally identifiable information) or which we collect when you interact with the Services.

  • User accounts:  You may be required to open an account directly with by completing the registration process and providing true, accurate, current and complete information about yourself.  Personal information may also be required to use or participate in certain Services, such as registering for games and special game events, player match-ups and online competitions, contest registration and prize acceptance, customer support and/or technical service requests, marketing surveys and email campaigns, product and service orders, and requests from third party service providers. Information collected will vary depending upon the activity and may include your name, email address, phone number, home address, password, game user name, birth date, and credit card information.  Prize winners may be required to provide Social Security number or other identification number for tax purposes.  You may also complete a user profile that can be viewed by other users of the Services, which may include a profile picture, game user name and ID, other biographic details you provide, links to your profile on social networking websites, and other information.
  • Mobile devices:  Information collected from users of the Mobile Game App may include the mobile phone number, the mobile device identifier, IP address, the name associated with the device, the identity of the mobile carrier, the mobile phone model, country, geo-location and email address.  We may create and assign an account number or ID to your mobile device.  You may sign up to receive SMS (short message service or text message) notifications sent to your mobile device. These messages will let you play the Mobile Game App from your mobile device and will let you know of in-game activity.  You can adjust the types of notifications you receive and when you receive them by adjusting your SMS notification settings.  You may also allow us to send push notifications and local notifications to your mobile device with game updates and other messages.  These notifications can be adjusted on your mobile device settings or through the Mobile Game App.
  • Social networking websites:  The Services may be offered to you through a social networking website through which you may access this Site.  You may be able to use your user account or user ID from the social networking website.  By accessing or using a game, application, or activity on this Site, you may be granting the social networking website permission to share your e-mail address and any other personal information with us, including name, address, gender, age, profile picture and information, occupation, hobbies, interests, and zip code. When you access and use the Services through on a social networking website, we may collect information regarding your use, as well as other information from your social networking website profile in accordance with the website’s terms of use.  If we provide you the ability to import your address book contacts to invite them to join you in using the Services, if you invite someone into your social network , or if you send messages through the Services, we may also collect and maintain the information associated with those messages, including your contact’s email address, ID number and any content.
  • Billing information:  You may be required to pay for certain Services, including an exchange for Virtual Currency, a purchase of Virtual Goods, and upgrades.  Current, complete, and accurate information for your billing account is required and you must also promptly update all information, such as a change in billing or shipping address, credit card number, or credit card expiration date.
  • Content:  You may make your personal information available when you are allowed or invited to share or participate in games, blogs, message boards, online forums and other functionality.  The Services may also provide you with the opportunity to create, submit, post, display, transmit, perform, publish, distribute or broadcast content and materials to and/or to or through this Site or the Mobile Game App.  This may include text, writings, graphics, comments, forum posts, chat posts, communications, messages, profiles, personally identifiable information, suggestions, links, e-mails, music, sound, graphics, images, pictures, video, software, technology, code and other material and information perceived, made available, or emanating to and/or from the Services (collectively, “Content”). Content also includes any feedback, comments, or suggestions you may provide regarding the Services, other Content, this Site, or the Mobile Game App, including any responses provided through user surveys.


How We Collect Information

We may also gather and assess certain technical non-personal information, including the number of visitors using the Services, feature usage, game play statistics and scores, user rankings, and click paths.  This information is collected from various sources.

  • Cookies and other technologies:  When you access or use the Services, we collect information about your computer system or mobile device and your interaction with the Services.  We may use mobile device application development software, metrics tools, and other analytics technologies to capture aggregate statistical usage information when you use the Services.  Our computer servers may automatically collect and store certain information about you through built-in tracking features (e.g., web bugs, beacons or tags) or technology known as “cookies” to send a small file to your computer’s hard drive. A cookie identifies you as a unique user to obtain information regarding your use of the Services.
  • This information collected may include data about your hardware system, including your IP address (the numeric address that may be assigned to your computer by your ISP) from which you accessed the Internet, hard drive serial number, browser type, browser language, platform type), mobile device, as well as and website usage, including domain names, landing pages, pages viewed, ads or links are clicked, viewing order, amount of time spent on particular pages, date and time you accessed the Services, other browser history, your game use, how much time is spent playing the game, game statistics, and feature usage.
  • Third party ads:  Advertising and other content may be provided by ad serving companies that gather information about your online activities through the use of cookies.  This Privacy Policy covers the use of cookies by only, but not the use of cookies by third parties, including advertisers.  The information gathering practices of other parties are subject to their own policies.
  • Internet log file:s  We may maintain log files which contain IP addresses to monitor website or mobile device traffic, to troubleshoot technical problems, and to report aggregate information to third party advertisers.  For website security purposes, and to ensure that the Services remain available to all users, we also monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.


How We Use Information uses your name, email address and other personal information we have collected to allow you to access and use the Services, to fulfill your specific requests, to process your transactions, to administer your inquiries, to provide service notifications, and to solicit your feedback and input.  If you choose this feature, we may also use your personal information to send messages about new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest.

We use personal and non-personal information, in individual or aggregated form, to analyze the behavior and preferences of our visitors, to troubleshoot technical problems, to enforce our Terms of Use Agreement, to ensure proper functioning and to improve the Services.  We also combine non-personal information with personal information, to determine the kinds of content that you would like to view, to assist any advertisers in targeting their advertising, and to tailor the Services or game play experience to your preferences or interests.

Sharing Information

We will not share or disclose your personal information to any third parties without your consent.  However, we may disclose information about you to third party contractors in order to provide the Services, to resolve service problems, to correct errors in the Services, to communicate with you, to provide you with advertising and promotional information in connection with the Services, and to enhance your experience on this Site or your mobile device.  Third party contractors may also use your personal information to provide email delivery, product, prize or promotional fulfillment, contest administration, credit card processing, shipping or other Services.  When requesting these Services, you may be asked to provide your personal information, including your name, mailing address, telephone number and email address.  When the third party contractors have access to the personal information that you provide to us, we require them to adhere to our privacy policies and to protect the confidentiality of your personal information while performing their duties for us. These third parties are prohibited from using your personal information for any other purpose without your specific consent.

Your Content

The Services may allow or invite you to chat or participate in blogs, message boards, online forums and other functionality, and may provide you with the opportunity to create, submit, post, display, transmit, perform, publish, distribute or broadcast content and materials to and/or to or through this Site or your mobile device.  These materials may include, without limitation, text, writings, graphics, comments, forum posts, chat posts, communications, messages, profiles, personally identifiable information, suggestions, links, e-mails, music, sound, graphics, images, pictures, video, software, technology, code and other material and information perceived, made available, or emanating to and/or from the Services (collectively, “Content”). Content may be provided by you or third parties, and also includes any feedback, comments, or suggestions you may provide regarding the Services, including any responses provided through user surveys.

You may choose to disclose information about yourself in the course of contributing Content, when playing games, in online chat rooms, blogs, message boards, user “profiles” for public view, or in similar forums.  Any personal or other information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality.

The Services allow interaction among players in which case your social networking website friends may see your name, profile photo, descriptions of your game activity, game profile, game name, and may reveal your social networking website ID number.  This information may allow others to view the public information associated with your social networking website account or Account.   Other players may also be able to send you friend requests or game requests through the social networking website.

Be aware that any personal information submitted while using any of the Services can be read, collected, or used by other users of the Services, and may be used to send you unsolicited messages. is not responsible for the personal information you choose to submit in these forums.  If you post a video, image or photo through the Services for public view, be aware that these may be viewed, collected, copied and/or used by other users without your consent.  Please refer to the Terms of Use Agreement for further information about posting Content.

Links to Other Websites

The Services may contain hyperlinks to other websites as part of advertising for other products and/or services that appear on this Site or your mobile device.  This may include offers hosted by third party advertisers to provide you an opportunity to interact with an advertisement offering.  None of these website links is meant as an endorsement, authorization or representation by of another website or its products and/or services.  These providers may require you to disclose personal information in order to register for and access such products and/or services.  If you click on a link to another website, including on an advertising hyperlink, you will be leaving this Site or the Mobile Game App.  Because we do control these websites, their privacy policies, or activities of any third parties, we are not responsible for any use of your personal information by other parties.   Before providing any personal information, be sure to review the privacy policies of the product or service providers from whom you request services or products, including any linked third party websites.

Legal compliance

You understand and agree that we may disclose personal information we may have about you to law enforcement or the appropriate civil authorities if required to do so by law, to comply with legal process, such as a search warrant, subpoena, statute, or court order issued by a governmental entity or other competent authority.  We may also do so if we have a good faith belief that disclosure is reasonably necessary to avoid liability, to prevent potential or actual injury, loss or damage, to protect our rights, property or operations, or that of our affiliates or the public. is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive.

Transfer of Information

You agree that we have the right to transfer your personal information in the event of a transfer of ownership, the business, and a substantial part of the assets of, whether by acquisition or merger with another company.  In such an event, we will notify you when your personal information is transferred and becomes subject to a different privacy policy.

International Safe Harbors

As part of our normal business operations, may transfer data to affiliated companies from time to time and may store information about visitors and players on servers located in the United States and on servers and equipment in other countries.   Personal information collected within Switzerland and the European Union may be transferred to, stored at, and processed by employees and others at a destination outside of Switzerland and the EU.  This may include, among other things, the processing of transactions and your payment details and the provision of support services.  By accessing the Services, you agree to the transfer, storing or processing of your personal information in this manner. voluntarily complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from EU member countries and Switzerland. agrees to adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement as described at

Accessing and Updating Your Information

You can access, correct or update your user account information or terminate your user account at any time by contacting us at  We reserve the right to retain your information in our files following your termination to resolve disputes, enforce our Terms of Use Agreement, for technical purposes, to comply with legal requirements, and for the security, integrity and operation aspects of the Services.  If you sent or posted Content on the Services, we may not be able to delete it.  You can also adjust certain aspects of information collection by reviewing the settings of your mobile device and the privacy management tools of the social networking website used to access the Services.

Information Security

The security of your personal information is important to us.  We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and in storage. When you send sensitive information (such as a credit card number) we encrypt that information using secure socket layer technology (SSL).  However, no method of data transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security.

Changes to Privacy Policy

We reserve the right to change this Privacy Policy in any way and at any time.  We will attempt to give you advance notice of any change in this Privacy Policy by posting on this Site or the Mobile Game App, or by sending a message informing you of the modified terms with a link to the posting on this Site or the Mobile Game App.  However, we reserve the right to make changes immediately, as determined in our sole discretion.  You agree to periodically check this Site or the Mobile Game App and to read any changes to this Privacy Policy.  Using our Services after any changes to this Privacy Policy become effective constitutes your acceptance of the new Privacy Policy.  If you do not agree to this Privacy Policy or any future changes to this Privacy Policy, you do not have permission to use the Services and you must immediately discontinue any further use of the Services.

Your California Privacy Rights

Under California law, residents of the State of California who have an established business relationship with or one of its subsidiaries may choose to opt out of the disclosure of personal information to third parties for direct marketing purposes.  Our policy, however, is not to disclose personal information collected online to a third party for direct marketing purposes without your approval.  If you choose to opt-out at any time after giving your approval, contact us at


If you have any questions about this Privacy Policy, please email or contact us at:

Spina Technology USA, LLC

Attn: Games Administrator

PO Box 30278,
Bethesda, MD 20824

United States of America

Tel:  310.445.6310