Privacy Policy

1. Purpose

This Privacy Policy forms part of the Hatch Games Terms of Service and is incorporated into them by reference. The words "Hatch", "we", "us" and "our" refer to Hatch Games. This Policy describes our online and offline information practices: what information we may collect, how we intend to use, store, protect, disclose and share it, and how you can opt out of a particular use or ask us to correct or change that information.

2. Scope

This Privacy Policy covers Personal Information processed by Hatch in the course of our business, including through our websites (each a "Site"), our mobile applications, forums, blogs and any other online or offline offering operated by or on behalf of Hatch, now or in the future (together, the "Services"). Everyone whose responsibilities include processing Personal Information on behalf of Hatch is expected to protect that data by following this Policy.

The Policy is intended to satisfy requirements worldwide, including those applying in North America, Europe, Türkiye, the APAC region and other jurisdictions. By visiting, installing, using or otherwise accessing the Services you accept this Privacy Policy and the Hatch Terms of Service, and you give your explicit and informed consent to the processing of your Personal Information as described here. Please do not install or use the Services if you do not agree.

Hatch is not responsible for the acts of Third Parties, for the content of their sites, for the use they make of information you give them, or for any services they offer. We may amend this Privacy Policy from time to time, and your continued use of the Services after a change means you accept it.

3. The Personal Information We Collect and How We Use It

What we collect — whether directly from you or from Third-party sources — and how we handle it depends on the nature of your relationship with Hatch and on what the applicable law requires. Personal Information may reach us in several ways: you may provide it directly while interacting with the Services, when you give feedback, answer a questionnaire or survey, enter a contest, post in a forum, or request a service or information from us; and certain information may be collected passively as you move through the Services, including through Cookies and similar technologies described below.

Our main reasons for collecting information are to provide and improve the Services, to administer your use of them, and to let you enjoy and navigate them easily. We aim to collect only what is relevant to those purposes. The sections that follow set out how we collect Personal Information and what we do with it.

3.1 The Categories of Personal Information We Collect

Hatch collects Personal Information about its current, prospective and former clients, customers, users, visitors and guests (together, "Individuals").

3.1.1 Information received from Third Parties when you install and play our games

If you play our games or use the Services through a connected Third-party application, or link the Services to one — for example Apple, Google, Amazon, or a Social Networking Site ("SNS") such as Facebook — Hatch may receive certain information about you from that provider. What we receive depends on the Third-party application, on your privacy settings there and, where relevant, on your friends' settings. When you connect to the Services through an SNS, the information we collect may include your first and last name, your SNS user ID and/or user name, your profile picture or its URL, location, sex, the login email you gave that SNS when you registered, your age range (for example, 21+), locale, application language, time zone, and the SNS user IDs of friends who are also connected to the Services.

When you use the Services, games or applications on a mobile platform, Hatch may collect and record information such as your unique device ID (persistent or non-persistent), your device's operating system, version, model, CPU, amount of RAM and free disk space, hardware type, Identifier for Advertising (IDFA), Advertising ID, device name, Game Center ID, and your location as derived from your Internet Protocol ("IP") address. This information helps us troubleshoot problems and understand how the Services are used.

Payments are handled by Third Parties, and Hatch does not collect, store or use personally identifiable payment information such as your name, address, credit card number, telephone number or email address for that purpose. We have no access to your card or bank account data. Third-party payment processors may, however, pass us non-financial details related to your purchase, such as which items were bought, so that we can fulfil your order.

You can manage what a Third-party application such as Facebook shares with Hatch by following that application's own instructions for changing privacy settings. You can also control parts of what is collected and used by opening your mobile device's settings page and reviewing each app's permissions. If you reach our Services from a Third-party application, or connect ours to one, please also read that application's terms of service and privacy policy.

3.1.2 Information you give us directly

When you use the Services or take part in certain activities — registering an account in our games, answering a survey, asking for a service or information, or contacting us directly — we may ask you to provide some or all of the following:

• Registering an account: when you create an account in the Services we may ask for Personal Information such as your name, email address, player name, password and profile details (for example, a profile photo).
• Contacting us: we may collect Personal Information such as your email address, telephone number or postal address when you ask about the Services, request customer or technical support, or otherwise get in touch.
• Reviews: from time to time you may share comments about our games and, in doing so, provide information that includes Personal Information. Everything collected through your participation is given voluntarily. We may use it to improve our products, Sites and Services, and in any other way consistent with this Policy.
• Fan pages, forums and public posts: Hatch may operate publicly accessible fan pages, blogs, private messages or community forums. Please be aware that when you disclose information about yourself in those places, the Site collects what you submit, including any Personal Information. Content you post to a public area of the Site is treated as public and is not covered by the privacy protections described here.
• Contests: Hatch may occasionally run contests and ask entrants for contact details such as an email address. If you enter, we may use your contact details to reach you about the contest and for other promotional, marketing and business purposes. Every entry form gives participants a way to opt out of communications that are not connected with awarding prizes.

3.1.3 Automated collection

We, and the Service Providers acting for us — such as Firebase, Google Analytics and AppLovin — may keep log files and use tracking technologies including Cookies, web beacons and tracking pixels. Through these technologies and other methods of web analysis we may automatically collect: your IP address; cookie identifiers; mobile advertising identifiers such as your IDFA or Advertising ID; your Game Center ID; the type of computer or mobile device you are using, together with its operating system, version, model and hardware type; other device identifiers assigned automatically when you connect to the Internet; browser type and language; your Internet service provider; the pages you visit before and after using the Services; the date and time of your visit and how long you spend on each page; the links you click and the pages you view within the Services; and other actions taken through the Services, such as your preferences. In some cases we connect this information with your social network ID, Device ID, Game Center ID or Advertising ID. Section 3.3 explains these tracking technologies in more detail.

3.1.4 Material you submit through the Services

You agree that Hatch may freely use the content of any communication you send through the Services, including any idea, invention, concept, technique or know-how disclosed in it, for any purpose, including developing, producing and marketing the Services. Hatch will not publish your name or otherwise make public the fact that you submitted material or information to us unless: (a) you give us permission; (b) we have first told you that material submitted to a particular part of a Service will be published or used with your name attached; or (c) the law requires it.

3.1.5 Ad networks

Hatch may show advertising within the Services. Advertisers may collect and use information about you such as: performance and contextual data about your game sessions; aggregated or de-identified information that is not meant to identify any individual user; and technical information such as your device identifier, Advertising ID and IP address. Ad networks may use this to deliver interest-based or targeted advertisements to you.

3.1.6 Social media widgets

The Services include social media features — such as Facebook and X (Twitter) buttons — and widgets such as the "Share" button or small interactive programs that run inside the Services. These features may collect your IP address and the page you are viewing, and may set a cookie so that they work correctly. They are hosted either by a Third Party or directly within the Services, and your interactions with them are governed by the privacy policy of the company that provides them. To protect you from an unwanted transfer of data to a social media provider, we use a technical safeguard known as the "two-click solution": you decide, either case by case or permanently, whether to activate a given sharing button and allow the transfer. A permanent agreement can be withdrawn at any time.

3.2 How We Use Your Information

Our main aims in using and storing the information we collect are to give you a better playing experience, to provide and improve the Services, to contact you, to carry out marketing and research, and to produce reports for internal use. We store information on servers provided by Amazon Web Services and Microsoft Azure, and may store information on servers, cloud platforms and equipment in other countries. We collect, store, use and process Personal Information for a range of business purposes, including:

• Providing the services or information you ask for. Hatch may use information about you to meet requests for the Services: to operate, improve and optimise our games and other Services; to create game accounts and let users play; to personalise the Services and understand our users and their preferences so that we can make the experience better; to give access to particular areas, functions and features; to tell you about in-game updates, new products and promotional offers; to send related messages including confirmations, technical notices, updates, security alerts, and support and administrative messages; to let players communicate with each other in our games or on our social media accounts; to answer your comments and questions and provide customer support; to prevent activity that may be prohibited or unlawful and to protect our players; to measure interest in the Services; to maintain internal quality control; and to verify an Individual's identity.
• Telling you about our games, products and services. Hatch may use Personal Information to send you material about offers, products and services that may interest you, including new games, content and features. We may do this through in-game offers, push notifications, social network notifications, online or offline marketing, or email, as the law allows: to deliver advertising, marketing and promotional information; to tailor content, advertisements and offers; to tell you about products, services, special offers or events that may interest you; and to notify you about rewards, surveys, contests and other promotional activities or events run or sponsored by us or by our Business Partners. You may opt out at any time, at no cost, by using the opt-out link included in every marketing email, by turning off notifications in your device or SNS settings, or by writing to contact@hatch.games.
• Sending push notifications. Hatch may occasionally use push notifications in our mobile applications to send game updates, high scores and other Service-related notices that may matter to you. You can opt out of these at any time by turning them off in your device settings.
• Using anonymous and aggregated information. We may use Personal Information and other information about you to create anonymised and aggregated information — for example de-identified demographic or location information, information about the computer or device you use to reach the Services, or other analyses we produce. Aggregated and anonymised information serves a number of functions, including measuring visitors' interest in and use of different parts or features of the Services. Because it is not Personal Information, we may use it in a number of ways, including research, internal analysis, analytics and any other lawful purpose, and we may share it within Hatch and with Third Parties for our purposes or theirs, in a form designed to prevent anyone from identifying you.
• Providing services through mobile devices. We may offer Services designed for mobile devices. We collect certain information your device sends when you use them, such as a device identifier, user settings, location information, mobile carrier and operating system. Mobile versions of our games may require you to log in with an account; where they do, information about your use of them may be associated with that account.

3.3 Cookies, Pixel Tags, Web Beacons, Analytics and Interest-based Advertising

We, and Third Parties that supply content, advertising or other functionality within the Services, may use Cookies, pixel tags and similar technologies ("Technologies") to collect information automatically. These are small data files placed on your computer, tablet, mobile phone or other device (together, a "device") that let us record certain information whenever you visit or interact with our sites, services, applications, messages and tools, and recognise you across devices.

• Cookies are small text files placed in a visitor's browser to store preferences. Most browsers let you block and delete them, although the Site may not work properly if you do.
• Pixel tags and web beacons are pieces of code embedded in a page that collect information about how users engage with it — recording, for example, that a user visited a particular page or clicked a particular advertisement.
• Social media widgets. Our website includes social media features such as the Facebook "Like" button and LinkedIn widgets, which may include a "share this" button or other interactive mini-programs. They may collect your IP address and the page you are visiting, and may set a cookie so that the feature works. They are hosted either by a Third Party or directly on our website, and your interactions with them are governed by the privacy policy of the company that provides them.
• Analytics. We may use Google Analytics, including its Demographics and Interest Reporting, to collect information about visitor behaviour and demographics across parts of the Services and to help us develop our content. This analytics data is not tied to any Personal Information. The information generated by Google Analytics about your use, including a truncated version of your IP address, is transmitted to a Google server in the United States and stored there. Because we have enabled IP anonymisation, your IP address is truncated by Google inside a member state of the European Union or the European Economic Area before being transmitted to the United States. You can read more at google.com/policies/privacy/partners, and you can opt out of Google's collection and processing of data generated by your use of the Services at tools.google.com/dlpage/gaoptout.

Our use of these Technologies falls into the following broad categories:

• Operationally necessary. Technologies needed to run our sites, services, applications and tools — including those that give you access to them and those required to identify irregular behaviour, prevent fraud and improve security.
• Performance-related. Technologies that let us assess how our websites, applications, services and tools perform, including as part of the analytics that help us understand how visitors use them.
• Functionality-related. Technologies that let us offer enhanced functionality when you access or use our sites, services, applications or tools — recognising you when you sign in, for example, or keeping track of the preferences, interests or previously viewed items that let us present content better.
• Advertising and targeting. First-party or Third-party Cookies and web beacons used to deliver content, including advertisements relevant to your interests, on our sites or on Third-party sites. This includes technologies that help us understand how useful an advertisement or piece of content has been to you — whether you clicked it, for instance. If you would rather opt out of the Technologies we use, you can do so by blocking, deleting or disabling them to the extent your browser or device allows.

Opting out of cookie tracking. You can set your browser to warn you when a Cookie is about to be placed on your computer, or to limit the types of Cookies you accept. Flash Cookies behave differently from browser Cookies, and the cookie management tools in a browser may not remove them. Please note that disabling Cookies may cost you some of the features and functionality of the Services, because Cookies are needed to track and improve your game activity.

3.4 Third-party Websites, Social Media Platforms and Software Development Kits

The Site may contain links to other websites, and other websites may link or refer to our Site or Services. We do not control those domains and sites, we do not endorse, screen or approve them, and we are not responsible for their content or their privacy practices. We encourage you to read the privacy policy of every website and application you interact with. You visit them at your own risk.

The Services may include publicly accessible blogs, community forums and private messaging features, and the Site and our other Services may contain links to, and interactive features from, various social media platforms such as widgets. If you already use those platforms, their Cookies may be set on your device while you use our Site or Services. Please be aware that Personal Information you voluntarily include and transmit in a publicly accessible blog, chat room, social media platform, open forum or similar place may be seen and used by others without restriction. We cannot control how your information is used when you interact with a social media platform, and by using such services you accept the risk that the Personal Information you provide may be viewed and used by Third Parties for any number of purposes.

3.5 Third-party Payment Processing

We may sell virtual items or merchandise through the Services. When you make a purchase, payment is processed by a Third-party application — including the Apple App Store, Google Play Store and Amazon Appstore (together with any similar application, the "App Stores") and Social Networking Sites such as Facebook. That Third-party application may collect certain financial information from you in order to process the payment on behalf of Hatch, including your name, email address, address and other billing details. The App Stores do not share this information with us.

4. How We May Disclose Your Information

We may share your information as described in this Privacy Policy — to provide the Services together with our Third-party Service Providers, to meet legal obligations, and to protect and defend our rights and property — or with your consent.

• Service Providers. We may share information we receive with Service Providers. The categories of Service Provider (processors) we entrust with Personal Information include those providing: (i) IT and related services; (ii) information and services you have requested; (iii) payment processing; (iv) customer service; and (v) other support connected with delivering the Services. Hatch has contracts in place with these providers that forbid them from using or sharing Personal Information except as necessary to perform the services we have contracted for, or to comply with applicable legal requirements.
• Business Partners. Hatch may share Personal Information with Business Partners and affiliates for our internal business purposes and theirs, or to provide the Services you have requested. We may also give Personal Information to Business Partners with whom we jointly offer products or services; in those cases the partner's name will appear alongside Hatch's. We require our affiliates and Business Partners to agree in writing to keep Personal Information held on our behalf confidential and secure, and not to use it for any purpose other than the one for which we provided it.
• Display to friends and other players. Our Services let you interact with other players. If you play through a social network, or register through one (for example Facebook Connect), your friends on that network will see your name, profile photo and descriptions of your game activity. Other players — whether or not they are your friends on that network — may also see descriptions of your game activity, communicate with you inside the Services where a chat feature exists, and view your game profile, which may include your name or game name and your profile photo. In some cases your profile photo can reveal your social network ID or player ID, and access to that ID may let others see the public information attached to your related profile or game account. Content you post may also appear in the chat features of our games. We are not responsible for the privacy practices of other users who see and use information you have posted.
• Marketing, interest-based advertising and Third-party marketing. Within the Services, Hatch may allow Third-party advertising partners to set tracking tools such as Cookies and collect: performance data, for example the number of clicks on an advertisement; technical information such as IP addresses, non-persistent device identifiers like an Advertising ID, and de-identified persistent device identifiers such as a hashed Android ID; your social network ID; contextual data about your play, such as your level and session length; and pseudonymous data that does not directly identify you, such as operating system name and version, device model and time stamp. These partners may use this information, together with similar information gathered elsewhere, to measure how effectively advertisements deliver targeted advertising about our games within their networks — a practice commonly called "interest-based" or "targeted" advertising. We may also allow access to other data collected by the Services in order to pass on information that may be useful, relevant or otherwise of interest to you.
• Disclosures to protect us or others, including as required by law. We may access, preserve and disclose your Personal Information, other account information and content where we believe doing so is required or appropriate: (i) to comply with law enforcement or national security requests and legal process such as a court order or subpoena; (ii) to respond to your own requests; (iii) to protect your rights, ours or those of others, and our respective property and safety; (iv) to enforce Hatch's policies or contracts; (v) to collect amounts owed to Hatch; (vi) where we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation into suspected or actual unlawful activity; or (vii) where we believe in good faith that disclosure is otherwise necessary or advisable. Server logs may also be reviewed from time to time for security purposes, such as detecting unauthorised activity on the Services; in such cases log data containing IP addresses may be shared with law enforcement so that they can identify users in the course of their investigation.
• Merger, sale or other transfer of assets. If Hatch is involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of a service to another provider, your information may be sold or transferred as part of that transaction, to the extent permitted by law or contract. Should that happen, Hatch will endeavour to require the recipient to use Personal Information in a way consistent with the Privacy Policy in force when the information was collected.

5. International Transfer

Personal Information collected by or through Hatch may be stored anywhere in the world, including in Türkiye, the United States and the European Union, in the cloud, on our own servers, and on the servers of our affiliates or Service Providers. When we transfer your Personal Information internationally we take reasonable steps to see that it is handled securely, lawfully and in the manner described here. Privacy laws differ from one jurisdiction to another, so the laws applying where your information is transferred to, stored, used or processed may differ from those applying where you live. By providing information to Hatch you consent to it being stored in these locations.

If you use the Services from the European Union, or from another region whose laws govern the collection and use of data, please note that you are agreeing to the transfer of your information to Türkiye and the United States and to the processing of your data globally. By choosing to visit the Site, use the Services or otherwise give us information, you agree that any dispute about privacy or about the terms of this Privacy Policy will be governed by the laws of Türkiye, and that any dispute arising in connection with Hatch or the Site will be resolved in accordance with our Terms of Service.

6. Opting Out (Right to Restrict Processing)

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Hatch processing your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further processing by opening an in-game support ticket or by writing to contact@hatch.games. Even after you opt out we may continue to collect and use anonymised, non-personal information about your activity in the Services. Please note too that some records — those relating to payments or customer service matters, for example — must be kept for legal and accounting reasons, and that we may be unable to delete content you have sent through or posted on the Services.

• Email. If you receive an unwanted email from us, use the unsubscribe link at the foot of the message to opt out of future emails. We will act on your request within a reasonable time. You will still receive transactional emails about products or services you have requested.
• Mobile devices. Hatch may occasionally send push notifications through our mobile applications with game updates, high scores and other notices that may interest you. You can opt out of these at any time by changing your device settings. Hatch may also collect location-based information when you use our mobile applications; you can opt out of that in the same way.
• Cookies and interest-based advertising. As noted above, you can stop or restrict the placement of Cookies on your computer, or remove them, by adjusting your browser preferences. To learn about and manage Flash Cookies, visit the Adobe website and use the Global Privacy Settings Panel. The online advertising industry also runs websites where you can opt out of targeted advertising from partners taking part in self-regulatory programmes — the Network Advertising Initiative Consumer Opt-Out page, Your Online Choices, and the Digital Advertising Alliance Opt-Out page for advertising in the United States. You can also exclude yourself from Google Analytics. These opt-out tools are provided by Third Parties; Hatch neither operates nor controls them, nor the choices advertisers and others offer through them.

On a mobile device you can reset the Advertising Identifier, such as the IDFA, from your settings page, which prevents further use of existing behavioural data tied to the previous identifier. Depending on your platform provider, you may also be able to install apps such as the Digital Advertising Alliance's "AppChoices", which give you control over the collection and use of cross-app data for tailored advertising. As with the web tools mentioned above, these are provided by Third Parties and are outside Hatch's control. To be clear: whether you use our opt-out or an industry one, cookie-based opt-outs must be applied on every device and in every browser where you want them to take effect. Opting out on your computer's browser will not opt you out on your mobile device.

7. Rights of Access, Rectification, Erasure and Restriction

You have the right to ask for access to your Personal Information and for its rectification or erasure, to ask us to restrict processing, to object, and to data portability. The general right to object applies to every type of processing described in this Policy. Unlike an objection to processing for direct marketing, which we must always honour, we are obliged to act on other objections only where you give specific grounds relating to your particular situation.

Where applicable law allows, you can open a support ticket inside our games or send an email to contact@hatch.games to ask for access to, a copy of (a port of), rectification of, or the erasure of Personal Information Hatch holds about you. Please include your full name, your user identifier, the email address linked to your account and a detailed description of your request. We handle such requests in line with applicable law.

Although Hatch makes good-faith efforts to give Individuals access to their Personal Information, there are circumstances in which we may be unable to — for instance where the information is legally privileged, where disclosure would compromise another person's privacy or other legitimate rights, where the burden or expense of providing access would be out of proportion to the privacy risk involved, or where the information is commercially proprietary. If we decide that access must be restricted in a particular case, we will explain why and give you a contact point for further questions. To protect your privacy, Hatch will take commercially reasonable steps to verify your identity before granting access to your Personal Information or making any change to it.

7.1 Legal Bases (for users in the EEA, Switzerland and the United Kingdom)

If you are in the European Economic Area, Switzerland or the United Kingdom, we collect and process personal data about you only where we have a legal basis for doing so under the applicable EU, Swiss or UK law. The bases we rely on are:

• Contractual necessity — data we use in order to provide the Services you have asked for and we have agreed to provide, such as our games, customer support, chat functionality and third-party social network connectivity;
• Legal obligation — data we use to comply with a legal duty, such as keeping tax records or responding to a valid legal request for particular data;
• Legitimate interests — data we use for purposes that are not harmful to your privacy and that you can reasonably expect in the context of using our Services, such as marketing, advertising, analytics, research, and the optimisation of our games and other Services;
• Consent — relied on where our advertising partners and we collect data stored on your device, including device information, advertising identifiers, IP address, country and region. You give this consent when you agree to install our game, and you can withdraw it by uninstalling the game.

8. Data Retention

Hatch keeps the Personal Information described in this Privacy Policy for as long as you use the Services, or for as long as is necessary to fulfil the purposes for which it was collected: to provide the Services, resolve disputes, establish legal defences, carry out audits, pursue legitimate business purposes, enforce our agreements and comply with applicable law.

9. Security of Your Information

Personal Information you give Hatch is held on servers in secured facilities and protected by protocols and procedures designed to provide industry-standard security, including firewalls and data encryption. No server, computer, communications network or system, and no transmission of data over the Internet, can be guaranteed completely secure, so while Hatch works to protect your information we cannot warrant the security of anything you transmit to us or through the Services. By using the Services or giving us Personal Information you agree that we may communicate with you electronically about security, privacy and administrative matters connected with your use of them. If we learn of a breach of our security systems, we may attempt to notify you electronically — by posting a notice in the Services, sending you an email, or sending a push notification.

10. Children's Privacy

The Services are not directed to children under 13, and Hatch does not knowingly collect personally identifiable information from them. If you are the parent or legal guardian of a child under 13 — or under 16 in certain jurisdictions in the European Union — who uses our games, please contact us at contact@hatch.games. We will delete your child's Personal Information once we are able to identify the child, unless you give us verifiable consent for them to continue using our games.

11. Redress, Compliance and Accountability

If you have any question about our privacy practices or about this Privacy Policy, please write to Hatch at contact@hatch.games. We will look into your concerns and try to resolve any privacy issue promptly.

12. Changes to Our Privacy Policy and Practices

Revisions. We may revise this Privacy Policy at our discretion, so please review it from time to time. If you continue to visit the Site and use the services offered through it after a change has been made, you consent to that change.

Publication of the revised Policy. If there is a material change to this Privacy Policy, Hatch will notify you by email or in any other way the law requires. We publish amendments on this page, and the revised version takes effect as soon as it is posted, or on notice where that applies. If you are concerned about how your information is used, bookmark this page and read the Policy periodically.

New uses of Personal Information. Before we use Personal Information for a new purpose you did not originally authorise, we will endeavour to explain that purpose and give you the chance to opt out. Where an Individual's consent to processing is required by law or by contract, Hatch will endeavour to comply with that requirement.

13. California Privacy Rights

California law lets users who are California residents ask us, once a year and free of charge, for a list of the Third Parties to whom we disclosed their Personal Information (if any) for those parties' direct marketing purposes during the previous calendar year, together with the categories of Personal Information disclosed. Hatch does not share Personal Information with Third Parties for their own marketing purposes.

14. Contact Details of the Data Controller

If you have any question about our privacy practices or this Privacy Policy, please contact the Hatch data protection contact by email at contact@hatch.games.