Privacy PolicyPrivacy Policy

1. Introduction

Pritto Prisoner is published by Initiate Games Inc. The primary language of this document is English; other languages are provided for reference only.

If you are here, you have reached us by visiting www.priprigame.com or one of the other websites owned and operated by Initiate Games Inc. and its subsidiaries (the “Site”), or by registering or installing any of Initiate’s interactive software product offerings (the “Games”), our content, events, applications, services, patches, updates, or tools, or by using any of our other online or offline services (collectively, the “Services”). Initiate Games Inc. is committed to protecting your privacy. This Privacy Policy explains our collection, use, disclosure, retention, and protection of your personal information, as well as your rights to your data under applicable U.S. and international law.

This Privacy Policy applies to the Site, our Games (including without limitation enhancements and updates thereto), and our Services where this Privacy Policy is referenced, regardless of how they are accessed. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.

This Privacy Policy describes:

• the information we collect, how we collect such information, and the purposes of our collection;
• how we use and with whom we share such information;
• how you can access and update your information; and
• how we protect the information we store about you.

Residents of California, Colorado, Connecticut, Utah, and Virginia should review Section 14 for additional information on how personal information is handled and what privacy requests may be available under applicable law. Although we do not sell user data, we will provide notice if circumstances change.

2. Information We Collect

When you interact with our Services, we may collect and store information from you directly as described below.

2.1 Registration Information

You may be asked to create a user account through our system before you can play or access certain Games or features (your “Account”). Your Account may be used to enjoy multiplayer and player-versus-player modes available in some of our Games and may be used to publicly identify you as part of the social features of the Services, which may include user-to-user interaction, chat or messaging functionality, competitive gameplay and matchmaking, and other similar features.

We may also offer you the option to complete a user profile or provide information in a player dashboard that is accessible and editable only by you, and that may be viewable to other Initiate users. Your user profile may include a profile photo, an Initiate username, biographic details that you provide, details about the Games you play, and an Initiate user ID number that is created by Initiate and used to identify your profile.

Your Initiate username may be public and may be shown to other users, but we will only permit access to information that is considered public or that you have designated as public in your user profile settings. The information you include in your profile is optional, and we advise you to limit the information you share through this feature if you have concerns about your privacy.

Your Account will be used to identify your transactions and payment history, player sessions, player ratings or rankings, individual user settings, customized characters, in-Game currency, and other in-Game features that we may make available from time to time. We do not condone the sharing of your Account information or password with anyone, and we will never request such information in order to provide Services to you.

2.2 Payment Information

When you order any good or service through any of our Games, the purchase of the license will be made directly through our payment, currency, and account solutions providers, which may collect relevant information in connection with such purchase.

Please review the terms and conditions and privacy policies of the third-party payment processing service provider for more information. In addition, each time you make a purchase of a license, we will collect information relating to that in-app purchase, including but not limited to player ID, device ID, session ID, your current available currency, the USD value of the currency, and other information related to the transaction. Our payment processing service provider may also retain this information to enable you to purchase additional items through our Game without having to re-enter it each time. Please note that purchases from third parties may also be subject to additional policies.

2.3 Information Collected by Customer Support

When you ask for assistance from our customer support team, we will collect and store the contact information you provide (generally your name and email address), information about your gameplay or activity on the Games, and your username or ID number. We will also store the correspondence and any information contained within.

2.4 Technical and Usage Information

When you access our Services, we may collect (i) certain technical information about your gaming device, mobile device, or computer system, including IP Address, device ID (Google Advertising ID or other identifiers), anonymized player and account ID, session ID, marketplace purchases, transaction history and currency information, game play and player information, and the current version of your operating system; and (ii) usage statistics about your interactions with the Games. In certain Games we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, character name, or email address. We may also access your contacts to enable you to invite friends to join you in the Games. This information is typically collected through the use of third-party software development kits.

2.5 Location Information

We may acquire certain player data, which could include information about the territory or region from which you access our Games by converting your IP address into a rough geolocation. We may use location information to improve and personalize our Services for you.

3. How We Collect Your Information

We may collect information about you in any one or more of the following ways:

3.1 Communications Features

You may be able to take part in certain activities through our Services that give you the opportunity to communicate or share information not just with Initiate, but also with other users of our Services. These include:

• participating in player forums and message boards;
• posting public comments to other users’ profiles or gameboards;
• sending private messages or invitations to other users, either directly through the Games or to their email accounts;
• sharing user generated content or photos, if such feature is made available; and
• chatting with other users.

We may use, record, and store archives of these communications on Initiate’s servers to protect the safety and well-being of our users and Initiate’s rights and property in connection with the Services.

3.2 Cookies and Automated Information Collection

When you access our Services, we may collect certain technical information in order to (i) analyze the usage of our Services; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf may use Log Files and tracking technologies to collect and analyze certain types of technical information, including Cookies, Flash Cookies, and Web Beacons.

“Log Files”means certain information about how a person uses our Services, including both registered and unregistered users (a “User”). Log Files may include information such as a User’s Internet Protocol (IP) addresses, device name, user language, time played, platform type, number of page clicks, player levels, player history, the amount of time spent on particular levels, campaign progression, player-versus-player sessions and rankings, Game state and the date and time of activity on our Site or the Games, webpage interactions and pages viewed, and other similar information. In some cases, we may associate this information with your account ID number for our internal use.

“Cookies”are small text files that are placed on your device by a web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some Third-Party Service providers (including third-party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third-parties.

“Web Beacons” (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to know if a certain page was visited or whether an email was opened, to advertise more efficiently by excluding our current users from certain promotional messages, to identifying the source of a new installation, to delivering ads to you on other websites. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an email).

“Flash Cookies” are local shared objects, which help us to prevent fraud, remember your in-Game preferences, and speed up load times.

Please note that companies delivering advertisements in the Games or on our Site may also use cookies or other technologies, and those practices are subject to their own policies.

3.3 Other Sources

We may collect or receive information from other sources including: (i) other Initiate users who choose to upload their contacts, and (ii) third-party information providers. We do not condition participation in our Services on you providing more personal information than is reasonably necessary for that activity.

4. How We Use Information We Collect

In general, we collect, store, and use your information to provide you with a customized experience. For example, we may use information collected from you in any one or more of the following ways:

We may use your personal information to fulfill a contract with you and provide you with our Services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good. This includes:

• to create Accounts and allow you to play certain Games;
• to facilitate in-app purchases;
• to enable user-to-user communications;
• to provide technical support and respond to user inquiries;
• to prevent, detect, mitigate, and investigate fraud or potentially illegal activities, and enforce our Terms of Service;
• to provide other services requested by you as described when we collect your information;
• to notify users of in-Game updates, or updates to our Terms of Service or this Privacy Policy; and
• to provide in-Game leader boards and matchmaking, and to promote in-Game player achievements.

We may use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes:

• to track user retention and aggregated gameplay information to improve the overall user experience for Initiate’s products and services;
• to solicit input and feedback to improve Initiate’s products and services and customize your user experience;
• to use general location information to provide you with location based services (such as matchmaking, search results, and other personalized content); and
• to contact you with information that we reasonably believe may be relevant to you.

With your consent, we may use your personal information:

• to inform users about new products or promotional offers.

If you have provided your email address to us, we may use it to respond to (i) customer support inquiries, and (ii) keep you informed of your in-Game activity, including comments from friends and notifications about in-Game status. With your consent, we may also send promotional email messages (“Promotional Communications”) directly or in partnership with parties other than Initiate. Each Promotional Communication will generally offer recipients choices about withdrawing consent so you no longer receive additional messages.

5. Sharing of Your Information

We may share your information (in some cases personal information) with third parties in the following circumstances:

5.1 Third-Party Service Providers and Third-Party Products and Services

We may provide your information to third-party companies to perform certain services, including but not limited to payment processing, data analysis, email delivery, hosting services, customer service, and to assist us in our marketing efforts. We direct all such Third-Party Service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on Initiate’s behalf.

We do not routinely share personal information with third parties except as may be necessary to provide Services to you. We may share (i) aggregated information (information about you and other users collectively, but not specifically identifiable to you); (ii) anonymous information; (iii) certain technical information (including IP Addresses and device or player IDs) to develop and deliver Services to you, including payment solutions; (iv) personally identifiable information, including payment information, address, phone number, identify verification, credit card number, and other personal information as may be necessary to provide such Services.

We may also allow third parties to collect these types of information within the Games and they may share it with us. Advertisers may collect this information through the use of tracking technologies like browser Cookies and Web Beacons.

We may disclose aggregated and anonymous information to describe the Services to prospective partners, advertisers, other third parties, and for other lawful purposes. We may use aggregate non-personally identifiable information for our own internal promotion or marketing purposes, and while we do not sell or rent your personally identifiable information to any third party, such aggregate non-personally identifiable information may be used to assist advertisers in targeting their services to specific user demographics.

In certain instances, you may need to opt-in or opt-out of advertising directly through our partners.

5.2 Friends and Other Players

In certain Games, friends and other players may be able to see your Game profile, which may include your name or a “game name” and your profile photo, which in certain cases can reveal your Account ID. Access to an Account ID may allow others to view the public information associated with your related Initiate Account. This information may also be shared with friends you invite to play certain Games.

5.3 Safety, Security and Compliance with Law

Your information may be disclosed: (i) when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a court order, search warrant, or subpoena); (ii) to satisfy any applicable laws or regulations; (iii) where we believe that the Games are being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and (v) in order to protect the rights or property of Initiate, including to enforce our Terms of Service.

5.4 Sale or Merger

In the event that Initiate undergoes a business transition, such as a merger, acquisition by another company, change of control, or sale of all or a portion of its assets, we may transfer all of your information, including personal information, to the successor organization in such transition.

6. Our Policies Concerning Children’s Privacy

Generally, we direct our Services to a general audience and we do not knowingly collect personally identifiable information from users deemed to be children under their respective national laws. We may direct certain Services to an audience of all ages—including children. For these Services, we may restrict the collection of personal information on the Services from anyone, apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services from children, or get a parent’s permission to collect personal information from children. If we become aware that a child has provided personal information without a parent’s permission, we will take steps to delete such information from our files as soon as possible. We urge parents to instruct their children to never give out their real names, addresses, or phone numbers without permission.

If you are a parent or guardian and wish to review or change the information we may have about your child, please contact us at privacy@initiate.fund. We will also be happy to remove your child’s information as appropriate.

7. How to Control Your Information

Under the European Union’s General Data Protection Regulation (GDPR), individuals residing in the EU and other territories that have adopted GDPR compliance or comparable regulation have a right to:

• Access your user data;
• Correct the data you have provided to us;
• Have information provided to you in a portable format;
• Request the deletion of the data we have collected;
• Restrict processing; and
• Object to processing or the legal basis on which we rely to process your data.

You may send an email to privacy@initiate.fundwith your request to exercise any of the rights identified above. Place the reason for your request (e.g., “Delete my Data” or “Correct my Data”) in the subject line and include your first name, last name, and email address in the body of the email. We will attempt to respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content through the Services, we may not be able to delete it. Accounts created with Initiate are considered active until we receive a user request to delete them or deactivate them. Any request to deactivate or delete an Account will not automatically result in information deletion unless so requested by the user, and only to the extent we are not required to retain such data to satisfy our legal obligations.

Please note that requests to restrict processing or delete your data may require the termination of your Account if we require the information subject to the deletion request to maintain your Account or otherwise provide gameplay Services to you.

We are unable to delete data controlled solely by third parties; for example, if you purchase a license to our Game through Steam, we won’t be able to delete your Game from your Steam library, nor the data collected by Valve in connection with your purchase or your Valve account. Similarly, if you access any of our Services through third-party social media or service platforms, such as Discord, or if you are routed to a Third-Party Service provider’s web page through our Services, you will need to make any deletion requests to those respective third parties separately.

Individuals Located in the EU:If we are unable to resolve any dispute with you, and you reside in an EU Member State, you may contact the regulatory authority in your Member State responsible for administering rights with regard to GDPR. You may also contact the reporting authority in the United Kingdom, the Information Commissioner’s Office, by following this link: https://ico.org.uk/.

Individuals located in the United States of America:For information and additional rights that may be available to individuals located in certain U.S. states, please review the “Additional Information for Residents of California and Certain Other U.S. States” at Section 14 of this Privacy Policy.

8. Opt-Out Options

8.1 Opting Out of Promotional Communications

You may choose to opt out of receiving promotional emails and product updates from Initiate by clicking on the “unsubscribe” link in any such email, or by opting out of such communications in your Game or Account preferences. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or email preference change will be processed promptly, usually within ten (10) business days.

8.2 Opt-Out Limitations

Please note that if you opt out of our Promotional Communications or other forms of communication, we may still email or communicate with you from time to time if we need to provide you with information and updates concerning this Privacy Policy or our Terms of Service, respond to a customer support or technical support inquiry, notify you of changes to your Account (including suspension or deactivation), respond to any customer service or technical support inquiry, request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons.

9. Security of Your Information

Accessing your Account, or any personally identifiable information stored through your Account, may be password protected and may provide for two-step authentication using a one-time password when first accessing our Services through any new computer or device, or when cookies are disabled. It is important that you protect and maintain the security of your Account and that you immediately notify us of any unauthorized use of your Account. We may encrypt the transmission of all information over public networks using secure socket layer (“SSL”) technology.

While we take reasonable precautions against possible security breaches of our Services, no website or internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Although we strive to protect your personal data, we cannot guarantee the security of your data while it is being transmitted through our Services; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access.

10. Sharing Your Information For Direct Marketing Purposes

We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by “opting in” to receive information from a third party that is participating in a sweepstakes or other promotion through our Services. If you do ask us to share your personal information with a third party for its marketing purposes, we will only share information in connection with that specific promotion, as we do not share information with any third party (other than our service providers) on a continual basis. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt-in to such use when you provide personal information through our Services.

11. Social Media Communications

You may be able to take part in certain activities through our Services that give you the opportunity to communicate or share information not just with Initiate, but also with other users of our Services, generally by engaging with official Initiate social media accounts. We are not responsible for your use of those services. If you communicate to us or other users publicly via our social media accounts, you are strongly encouraged to review the privacy policies of those services if you have questions about the use of your data. We only access the information you make available to the public on our social media pages and do not receive any information concerning your social media account from any social media platform.

12. Links to Other Sites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-Party Service”). Any information that you provide on or to a Third-Party Service or that is collected by a Third-Party Service is provided directly to the owner or operator of the Third-Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices, and policies of any Third-Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-Party Services that you access.

13. International Transfer

Your personal information may be transferred to, and maintained on, computers 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’re located outside the United States and choose to provide your personal information to us, we may transfer your personal information to the United States and process it there.

14. Additional Information for Residents of California and Certain Other U.S. States

Under the laws of California and certain other U.S. states, including, Colorado, Connecticut, Utah, and Virginia, the residents of those U.S. states who have an established business relationship with us may choose to opt out of our disclosure of personal information about them to third parties for direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for their direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email privacy@initiate.fund.

The California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) requires operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the websites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and sites has not yet been widely adopted. Currently, our computer system does not support, and cannot act on DNT signal headers that we may receive; accordingly, the choices that we provide you concerning our collection and use of personally identifiable information will continue to operate as described in this Privacy Policy. For information about Do Not Track, please visit: www.allaboutdnt.org.

14.1 How Do We Use Your Information?

In addition to the details provided in Section 4 (How We Use Information We Collect), residents of California, Colorado, Connecticut, Utah, and Virginia can refer to the table below, which identifies the categories of personal information we collect and provides examples of personal information in such categories.

We may obtain the categories of personal information listed in the table above from the following sources:

• Directly from our users. For example, from users who engage us for customer support or to provide customer feedback.
• Indirectly from our users. For example, through information we collect from our users in the course of providing customer support to them.
• Directly and indirectly from activity on our Sites or in our Games. For example, from Cookies embedded in our Sites or Games to measure Game metrics and other information related to improving our Services.
• From third-parties that interact with us in connection with the Services we perform. For example, from third party analytics or anti-cheat providers, or to ad mediators for the purpose of providing personalized advertising and marketing customized to you.

All such personal information is used as otherwise described in this Privacy Policy.

14.2 Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have not disclosed any personal information for a business purpose.

We may disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or Services we provide to you.
• Our vendors.

14.3 Your Rights To Access, And Control Your Personal Information

Depending on your location in the U.S., applicable state law may provide you with some or all of the data rights listed below. However, such rights are not absolute and may be subject to certain exceptions.

• Request access to or a copy of your personal information.
• Request deletion of your personal information.
• Request correction or modification of your personal information.
• Be informed about the personal information we collect and/or process about you, the sources of personal information, and the third parties with whom information was shared or sold and for what purposes.
• Withdraw consent, if processing is based on consent.
• Opt-out of the sale or sharing of your personal information (including targeted advertising).
• Opt-in/out of financial incentives.
• Limit the use and disclosure of your sensitive personal information.

14.4 Exercising Your Rights

To opt out of the sale or sharing of personal information, please follow the instructions at Section 8 (Opt-Out Options) above.

You can also submit requests to exercise your data rights through any of the methods in Section 16 (Contact Us). Note we may ask for some confirmation details before actioning any request. Please keep in mind that limiting use of, or deleting, your personal information may impact features and uses that rely on that information.

14.5 Verification; Authorized Agents

We may need to verify your identity in order to process your request to exercise your data rights, and we reserve the right to confirm your identity and residency, and in our discretion, deny your request if we are unable to verify your identity or residency. You may authorize someone to make a request to exercise your rights on your behalf (an authorized agent). Authorized agents will need to demonstrate to us that you have authorized them to act on your behalf, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity and/or verify the authenticity of the request directly with you.

14.6 Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will attempt to inform you of the reason and extension period in writing. The response we provide may also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

14.7 Appeals; Non-Discrimination

Users based in certain U.S. states, may have the right to appeal our decision regarding a request related to the data rights described above. If you wish to appeal a decision, please contact us through any of the methods in Section 16 (Contact Us). We will not discriminate against you for exercising any of your data rights. Unless permitted by the applicable law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

14.8 Other California Privacy Rights

Separate from the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our Sites who are California residents to annually request, free of charge, information regarding our disclosure of personal information (if any) to third parties for direct marketing purposes during the immediately preceding calendar year. While we do not share personal information collected online with third parties for their own direct marketing purposes and will not do so unless you agree to such disclosure, California residents may make such a request, by sending an email to privacy@initiate.fundor using the information provided in the “Contact Us” section below. In your request, please identify yourself as a California resident and provide sufficient information so we can take appropriate action, such as your name, email address or any additional information required.

15. Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. If we decide to make material changes to our Privacy Policy, we may notify you and other users by placing a notice on www.priprigame.com or by sending you a notice to the email address we have on file for you, and we’ll update the “Last Updated” date above. We may supplement this process by placing notices in the Games and on the Site. You should periodically check www.priprigame.com and this page for updates so that you remain aware of what information we may collect and how we use it.

16. Contact Us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please contact us at the following: