THIRTEEN GAMES, LLC

PRIVACY POLICY

Last modified: October 11, 2021

Your privacy is important and Thirteen Games, LLC (“Thirteen Games”, “we”, “our” or “us”) is committed to protecting it. This Privacy Policy explains how information about you or associated with you (“personal information”), is collected, used, and disclosed by Thirteen Games. This Privacy Policy applies to our websites, including http://thirteengames.com/ (the “Site”), games, in-game purchases, platforms (including the Apple or Google Play Apps), software services and related services (collectively, our “Services”). This Privacy Policy also details how Thirteen Games collects and uses information about you when contacting Thirteen Games by email. By accessing or using our Services, you signify that you have read, understood, and agree to our collection, use and disclosure of your personal information as described in this Privacy Policy. If you do not agree to the terms of the Agreement, do not use the Services.

We reserve the right to modify or change our Privacy Policy at any time after providing notice to you. The form of such notice is at our discretion.  By continuing to access or use our Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. 

The official language used by Thirteen Games is English. In the event of a conflict between the English language version of this document and any version translated into any other language, the English language version shall prevail. 

Thirteen Games undertakes commercially reasonable electronic, physical, and procedural security measures to protect the personal information of its customers and visitors.

  1. Information Collection

Information is provided by you or collected in or in relation to our Services or collected from other sources in order to: 

  • Provide, operate, improve and maintain our Services, game experience and your accounts; 

  • Personalize the game, content, and related services to you; 

  • Send technical notices, updates, security alerts, 

  • For support and troubleshooting reasons; 

  • Send support and administrative messages; 

  • Provide news and information about the Services and/or about our games and products; 

  • Facilitate sharing on social networks; 

  • Resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies; 

  • To administer, process, and examine claims of copyright infringements, or other violations of our Terms of Service; 

  • Make recommendations to you; and

  • Manage our Services and send you confirmations and important information about your account, purchases, subscriptions, and warranties. 

Visitors to the Site

The Site is essentially a brochure for our Services. The Site may collect information from you in the following ways:

  • Thirteen Games uses cookies for the limited purposes set out in TABLE ONE below to collect certain analytical and technical information. Thirteen Games relies on consent to collect this information, such consent obtained via you clicking to agree to such cookies being placed when you first visit the Site or otherwise changing the cookie settings so that such cookies are not placed. 


  • Should you choose to contact Thirteen Games via the Site, Thirteen Games will collect your e-mail address together with any other information that you submit in connection with such contact request. Thirteen Games relies on consent to collect this information because you choose whether to contact Thirteen Games or not and can choose how much personal information to provide to Thirteen Games in doing so. 

Emails Sent to Thirteen Games

When Thirteen Games receives emails, including complaints, we shall file any relevant document and may retain details of the complainant, and other individuals identified in the complaint. The retention of emails shall be stored in a secure environment and access to them will be restricted on a ‘need to know’ basis. Thirteen Games relies on the legitimate interests processing ground to collect the information set out in this paragraph. 

It is in Thirteen Games’ legitimate interests to collect such items of personal information listed here because this is necessary in order to analyze and respond to your email or complaint.

Information Collected through the Game

Where applicable, access and playing of certain basic game versions, experience of certain basic content and games features may not require registering of an account with applicable platform/service provides that are providing the game to you. However, in order to access and play complete games, access certain premium game functions, levels, content and features, you must register an account with the platform/service provides that are providing the game to you. You must then create an account with the platform/service providers’ platforms that hosts the game to access such premium game functions, levels, content and features etc. To create an account, you are required to provide certain mandatory information such as your name, your email address, account login etc., which is mandatory in order to establish an account. Thirteen Games and/or the platform/service providers (e.g., Apple App Store, Google Play) collects financial information on the terms and conditions set out in this Privacy Policy and/or the platform/service providers’ own privacy policies, which can be found on the respective platforms. Thirteen Games does not use financial information for any purpose other than processing payments. At this time, Thirteen Games does not personally collect or store your financial information and this information is all collected by the platform/service providers. Please refer to their respective privacy policies for more information on how they collect and use your personal information. 

Information Collected Through Other Sources

Our Services may provide links to third parties for your convenience and information. If you access those third party sites or services, you will leave our Services. Thirteen Games does not control those third party sites or services or their privacy practices, which may differ from Thirteen Games’ practices. We do not endorse or make any representations about third party sites or services. The personal information you choose to provide to, or that is collected by, those third party sites or services is not covered by this Privacy Policy. We cannot control the activities of third parties, and we have no responsibility for any use of your personal information by such third parties. Any information you choose to provide to third-party sites or services will be governed by the policies of those third-party sites or services. 

  1. Children

Thirteen Games does not knowingly collect or store any personal information from children under the age of 13 in the United States or under the relevant age threshold in other jurisdictions where the child is located. However, we may collect technical information required for delivering the service and for the support of our internal operations from all users of our Services. 

For more information, please refer to the Children Section in our Terms of Service. 

  1. Sharing Your Information


As a general rule, we will not share personal information that directly identifies you with independent third parties without your consent. Thirteen Games may, subject to its obligations to comply with applicable data protection legislation, share your information under the following circumstances:  

  • to respond to duly authorized information requests from police and governmental authorities;

  • to comply with any law, regulation, subpoena, or court order;

  • to investigate and help prevent security threats, fraud, or other malicious activity; 

  • in order to provide certain game functions; and

  • to enforce and protect the rights and properties of Thirteen Games.

In the event of a merger, consolidation, or sale or transfer of all or substantially all the assets of Thirteen Games or any of its affiliates, personal information from our customers and stored in our customer database will be transferred to the purchasing or new entity. However, the use of this information by any purchasing or surviving entity would be governed by the terms of this Privacy Policy, as amended from time to time, including any amendment after such transaction.

Your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Thirteen Games transfers personal information to the United States. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Any data or personal information stored by Thirteen Games from our users who reside in the European Union is processed in the United States. Thirteen Games shall process such user data in accordance with the requirements of the GDPR.  

  1. Legal Basis for Collecting your Personal Information

Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need your personal information to perform a contract with you, where the processing is in our legitimate interests and is not overridden by your data protection interests or fundamental rights and freedoms, or when we have a legal obligation to do so. Your consent to the Terms of Service and this Privacy Policy also constitutes the legal basis upon which we may collect your personal information.

  1. Security, Storage and Data Retention

Thirteen Games has implemented technology and polices designed to safeguard your privacy from unauthorized access and improper use. Any personal information collected will be stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. However, there is no such thing as perfect security. As a result, although we strive to protect personal information transmitted to us through or in connection with our Services we cannot guarantee personal information will be 100 percent secure.

Thirteen Games uses Firebase to store personal information. Firebase services are provided by Google. Thirteen Games also uses Firebase’s Authentication to collect a user’s email address for authentication purposes. Please refer to Firebase’s privacy policy at https://firebase.google.com/support/privacy. By using our Services, you agree to Firebase’s privacy policy. 

Thirteen Games has a retention policy in place with respect to any data it holds, that is designed to ensure that such data is not retained for longer than is reasonable in line with the purposes for which it was originally collected. If you wish to have your data deleted sooner, please contact us using the methods described in the Contact Us section. 

There may be some information that will be maintained for record-keeping and legal purposes, which will not be shared with third parties unless legally required. Some de-identified information or data collected in aggregate that does not contain personal information may be retained as well.

  1. European Union General Data Protection Regulation 2016/679 (“GDPR”)

GDPR addresses the protection of natural persons located in the European Union (“EU”) with respect to the processing of their personal information. GDPR recognizes that personal information shall be:

  • processed lawfully, fairly, and in a transparent manner;

  • collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;

  • adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;

  • accurate and, where necessary, kept up to date;

  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; and

  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

Under the GDPR, Thirteen Games is a Controller. For purposes of this Privacy Policy, a “Controller” is a legal or natural person, an agency, a public authority, or any other body who, alone or when joined with others, determines the purposes of any personal data and the means of processing it. As a Controller, Thirteen Games shall be responsible for, and shall be able to demonstrate compliance with, the foregoing principles. Therefore, to the extent GDPR is applicable to you, you have the right:

  • to request the correction or update of any personal information that is incorrect or incomplete;

  • to request the erasure of your personal information (the right to be forgotten);

  • to portability of your personal information;

  • to object to the processing of your personal information;

  • not to be subject to a decision based on automated decision-making, including profiling;

  • to withdraw consent to the processing of your personal information; and

  • to register a complaint with a supervisory authority (if you are located in the EU).

Unless otherwise prohibited by law, Thirteen Games will effect any such request without delay.

Under the GDPR, you have the right to be forgotten. If you reside in an EU territory, you may request the deletion of your personal data that we collect, store, or process. When you make your request, we will balance the privacy rights of the individual concerned with the interest of the general public in having access to the information, as well as the right of others to distribute the information. For instance, we may refuse to delete information regarding financial scams or other unlawful activities. If Thirteen Games receives a request for erasure, or a request to be forgotten, Thirteen Games will erase the personal data without undue delay (and no longer than 30 days after the request is received), where one of the following grounds applies:

  • the personal information is no longer necessary for the purpose for which it was originally collected or processed;

  • you withdraw your consent to the collection processing of your personal information; 

  • you object to the processing and there is no overriding legitimate interest for continued collection or processing of your personal data;

  • you believe that your personal information was unlawfully processed or collected (i.e., in breach of the GDPR);

  • your personal information must be erased in order to comply with an EU or an EU Member State law to which we are subject; or

  • such personal information was processed in relation to the offer of information society services to a child.

If you would like to submit a request for erasure (request to be forgotten), please use the form linked here.

You have the right to access and request the correction, amendment, or deletion of all of your recorded personal information that has been collected by us. If you wish to review your recorded personal information, please contact us at privacy@thirteengames.com:

You may contact us at any time with questions or requests regarding your personal information at privacy@thirteengames.com. 


If you write to us, please include your name, address, telephone number and let us know what kind of information you want to see. You may see and copy your information in person or, if you prefer, we will copy and send you your information. If you see any mistakes, let us know and we will review it. If we agree, we will correct our files. If we disagree, you may file a short statement of dispute with us. Your statement will be included with any data we disclose in the future. We will also send the statement to anyone you ask us to who received your information from us in the past two years.

  1. Sensitive data

We do not intentionally collect, process, transfer, or store Sensitive Data. For purposes of this Privacy Policy, “Sensitive Data” means data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data that concerns health, or data that concerns a natural person’s sex life or sexual orientation. 

  1. Contacting us

We value your opinions. If you have comments or questions about this Privacy Policy, please send them to privacy@thirteengames.com. 

Thirteen Games, LLC
Box #113
655 Deerfield Road, Ste 100
Deerfield, Illinois 60015

©2021 Thirteen Games, LLC. All Rights Reserved.

TABLE ONE

Cookies Used on the Site:

Cookie Type: Google Analytics for Firebase

Purpose: Allows Thirteen Games to track and understand user’s behavior, user experience, online content, device functionality and more. Google Analytics also allows us to support, maintain, and improve our Services.

Further Information: See Section 5 more for more information.