We at Monsarrat, Inc. (“Monsarrat”, Company”, “we”, “our” or “us”) know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing our website(s), games, products, software, newsletters, emails, services and applications (the “Services”) in any manner, you acknowledge that you have read this Privacy Policy, accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of the Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Information from anyone under the age of thirteen (13). If you are under 13, do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age thirteen (13), we will delete that information as quickly as possible. If you believe that a child under thirteen (13) may have provided us Personal Information, please contact us via email at: contact@monsarrat.com.

This Privacy Policy is intended to comply with all applicable laws, including, without limitation, the European Union’s General Data Protection Regulation (“GDPR”) and other similar laws throughout the world.

Will Monsarrat ever change this Privacy Policy?

We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the Services, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What Information does Monsarrat Collect?

Information You Provide to Us:

We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Information such as your email address and third-party account credentials (for example, your log-in credentials for Facebook, Google or other third-party sites). If you provide your third-party account credentials to us or otherwise sign in to the Services through a third party site or service, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy; for example, if you sign in to the Services through your Facebook account and you authorize us to access your list of friends, then you can be automatically connected to your friends on the Services. Certain information may be required to register with us or to take advantage of some of our features.

We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by clicking on the unsubscribe option in our messages.

Information Collected Automatically:

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. We may use third party analytics products that may transmit cookies to your browser or device. Also, if you click on a link to a third-party website or service, such third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services; for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

What Cookies and Tracking Technologies Does Company Use?

Company currently uses cookies in conjunction with our use of Google Analytics on the Company websites, including monsarrat.com.  The names of the Google Analytics cookies, along with their respective duration period (retention period) and a description (the purpose) are listed in the table immediately below this paragraph.  Additionally, these cookies are used (the purpose) to distinguish users and collect information about how visitors use Company’s websites.  We use this information to compile reports and to help us improve the website and the Services.  These cookies collect information in an anonymous form, including the number of visitors to the website, from where visitors to the website have come, and the pages of the website visited.

Cookie Name	Duration (Retention Period)	Description (purpose)
_ga	2 years	Used to distinguish users.
_gid	24 hours	Used to distinguish users.
_ga_<container-id>	2 years	Used to persist session state.
_gac_gb_<container-id>	90 days	Contains campaign related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out. Learn more.
Crumb	Session	· Prevents cross-site request forgery (CSRF). · Cookie
_xsrf	Session	Prevents cross-site request forgery (CSRF)
dbb	One Year	Identifies the session of a logged-in user inside and outside of a game
dbb_play	One Year	Identifies the session of a logged-in user inside a game
u	One Year	Identifies the browser session of any user inside and outside of a game
s	Session	Identifies the browser session of any user inside and outside of a game
CloudFront-Policy	One Year	Mediates Access to resources on the platform
CloudFront-Key- Pair-Id	One Year	Mediates Access to resources on the platform
CloudFront- Signature	One Year	Mediates Access to resources on the platform

 

To opt out of being tracked by Google Analytics across all websites visit https://support.google.com/analytics/answer/181881?hl=en.  For additional information on Google Analytics and its use of cookies please visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

We may also use other tracking technologies such as pixel tags, web beacons, or other web programming code from time to time. Such technologies may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Such technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. Such technologies may also enable us to send email messages in a format users can read, tell us whether mail has been opened, and ultimately allow us to reduce or eliminate messages sent to users. Information collected by or from such technologies will be treated as non-personal information. To the extent that Internet Protocol (IP) addresses or similar identifiers may be considered personal information by local law, however, such information will be treated as Personal Information. To the extent that non-personal information may also be combined with personal information, the combined information will be treated as Personal Information for the purposes of this Privacy Policy.

Information Collected From Other Websites and Third Party Authentication Sites / “Do Not Track Policies”

Through cookies that may be placed on your browser or device by third parties, including by third-party authentication services (such as Google, Facebook, etc.) information about your online activity may be collected after you leave our Services. Just like any other usage information that is collected, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support “Do Not Track” requests at this time.  As a result, information about your online activity may be collected by third parties both while you are using the Services and after you leave our Services. You may also be able to opt out of such tracking by those third parties that may place such cookies as noted above.

Our Policies Concerning Children’s Personally Identifiable Information

We do not knowingly collect personally identifiable information from someone we know to be a child under the age of thirteen (13) without prior parental consent. IF YOU ARE THIRTEEN (13) YEARS OLD OR YOUNGER, PLEASE DO NOT USE OUR SERVICES, INCLUDING, WITHOUT LIMITATION, OUR WEBSITES, AND DO NOT SUBMIT ANY INFORMATION TO THE SERVICES OR TO MONSARRAT.  Our websites and applications may contain features that may be attractive to children; therefore, children should not be granted access to any passwords or use of the parent or guardian’s account without direct monitoring and supervision by the parent or guardian. Company is not responsible for any unauthorized use of accounts, and we encourage everyone to protect their passwords and not disclose them to anyone.

Will Company Share Any of the Personal Information it Receives?

We may share your Personal Information with third parties as described in this Privacy Policy, including, without limitation, as follows:

1. Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual.
2. Analytics: We may use third party analytics services, such as Google Analytics, to grow our business, to improve and develop our Services, to monitor and analyze use of our Services, to aid our technical administration, to increase the functionality and user-friendliness of our Services, and to verify that users have the authorization needed for us to process their requests. These services may collect and retain some information about you. Google Analytics collects the IP address assigned to you on the date you use the Services, but not your name or other Personally Information. We do not combine the information generated through the use of Google Analytics with your Personal Information. Although Google Analytics plants a persistent cookie on your web browser to identify you as a unique user the next time you use the Services, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your use of the Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You may find additional information about Google Analytics at https://support.google.com/analytics/answer/12159447?hl=en. Finally, you can opt out of Google Analytics by https://support.google.com/analytics/answer/181881?hl=en.Certain of our third-party partners may deliver a file to you through the Services (known as a “web beacon”) from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site. You may be able to opt-out of web beacon tracking conducted by third parties through our Services by adjusting the “Do Not Track” settings on your browser; please note that we don’t control whether or how these third parties comply with “Do Not Track” requests.
3. Affiliated Businesses: In certain situations, businesses or third party websites with which we are affiliated may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account; for example, during Facebook signup we may use your full name to automatically set the “Display Name” of your Company account (such as your monsarrat.com account).
4. Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use an email delivery and processing company to send email messages to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Note that an “agent” may also be considered a “partner” in certain circumstances, and may be subject to the terms of the “Information that’s been de-identified” section above in that regard.
5. User Profiles and Submissions: Certain user profile information, including your handle, display name and description that you have set during sign-up or use of the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you add to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (in content that you create, comments that you post, in messages and in chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your handle or display name may also be displayed to other users if and when you send messages or comments or create content on the Services and other users can contact you through messages and comments. Additionally, if you sign into the Services through a third-party social networking site or service, your list of “friends” from that site or service may be automatically imported to the Services, and such “friends,” if they are also registered users of the Services, may be able to access certain non-public information you have entered in your Services user profile. Again, we do not control the policies and practices of any other third-party site or service.
6. Business Transfers: We may choose to buy or sell our business, certain games or apps, or certain portions or assets related to either, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
7. Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others.

The legal basis for our use and processing of Personal Information (and your personal data) for the noted purposes is based on the following:

 

Purpose of the processing	Legal basis for the processing
To provide you access to the Services, to administrate your user account and communicate with you regarding your user account and use of the Services.	Performance of contract. (Art. 6 para. 1 lit. b GDPR).
To keep you informed regarding Monsarrat’s products and services and company news, as well as other marketing communications.	Consent. Monsarrat’s legitimate interest.
To prevent, detect, investigate and take measures against criminal activity, fraud and misuse of or damage to our Services or network, and to take measures against other threats against Monsarrat’s or a third party’s rights.	Balancing of interests (Art. 6 para. 1 lit. f GDPR) where Monsarrat has pursued the following legitimate interests: ●       Monsarrat’s interest of investigating suspicion of and taking measures against misuse of or damage to our services or network; ●       Monsarrat’s and/or third party’s interest of investigating and producing evidence regarding criminal activity, fraud and other threats against its interest; ●       Monsarrat’s interest of establishing and exercising its legal rights; ●       Monsarrat’s and/or third party’s right to protect its safety or property; and ●       Competent authority’s interest of conducting law enforcement activities and collecting evidence for such purposes.
To comply with (i) applicable laws, regulations, court orders, government requests, and law enforcement agencies’ requests, or (ii) the extent otherwise required by applicable law.	Compliance with a legal obligation to which Monsarrat is subject.  (Art. 6 para. 1 lit. c GDPR).
To establish or exercise our legal rights or defend against legal claims, or protect the safety or property of our employees, contractors, customers, users or others.	Balancing of interests (Art. 6 para. 1 lit. f GDPR) where Monsarrat has pursued the following legitimate interests: ●       Monsarrat’s interest of pursuing its legal rights; and ●       Monsarrat’s interest of safeguarding its business relationships.
Marketing or email campaigns	Consent. (Art 6 para 1 lit. a GDPR)

 

Is Personal Information about me secure?

Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Company is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries.

What Personal Information can I access?

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

1. email address and password;
2. user profile information (including any handle or description of yourself, along with some of the content you have created, your avatar, etc.)

The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at contact@monsarrat.com.

Notwithstanding what is set out in the paragraph above or elsewhere in this Privacy Policy, if the processing of your personal data is subject to GDPR you have the following rights:

1. The right of access.This is your right to see what data is held about you by us and to receive certain additional information and copies of your personal data.
2. The right to rectification.The right to have your data corrected or amended if what is held is incorrect in some way.
3. The right to erasure.Under certain circumstances, including where your personal data is no longer required for the purposes it was collected, or your consent has been withdrawn, you can ask for your personal data to be deleted. This is also called “the right to be forgotten”.
4. The right to restrict processing.This gives you the right to ask for a restriction to processing of personal data, such as in the case where the accuracy of the data is disputed.
5. The right to withdraw consent. If processing is based on your consent, you have the right to refuse to provide your consent and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time.
6. The right to object. You have the right to object on grounds relating to your particular situation, that your personal data is processed. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for continuing to do so.
7. The right to data portability. This right entitles you to receive a copy of your personal data that you have provided to us in a structured, commonly used and machine-readable format, or request us to transmit your personal data to another data controller.
8. The right to complain. This means you may lodge a complaint before the competent data protection regulators.

You may exercise the rights referred to above or pose any questions or make any complaints regarding our data processing by contacting us, by sending an email to us at contact@monsarrat.com or write to us at the address below.  We will process such requests in accordance with applicable law.

Please note that if you object, restrict or otherwise refuse the processing of certain or all of your personal data and/or ask that we delete your personal data you might not be able to use some or all of the Services or certain aspects or elements thereof.

State Privacy Rights (and Similar Laws in Other Jurisdictions)

Your Privacy Rights Under California Law:

California law permits California residents to request from companies conducting business in California a list of third parties to which the company has disclosed personally identifiable information during the preceding year for direct marketing purposes as well as other details regarding types of information collected and how it is used. Company has not and will not share your personally identifiable information with third parties for their direct marketing purposes; accordingly, it will not maintain such a list of third parties. If you are a resident of California and want additional information confirming how the company does not share your personally identifiable information with third parties for their direct marketing purposes, or additional details regarding information that is collected, you may contact us at legal@monsarrat.com with the words “California Privacy” in the subject line of your email.

California Business and Professions Code Section 22581 permits California residents under the age of eighteen (18) who are registered users of our website or other aspects of the Services to request and obtain the removal of content or information that they have posted to public forums, such as chat rooms and bulletin boards. To make such a request, please contact us at legal@monsarrat.com with the words “California Privacy” in the subject line of your email, or write to us at the address above and include a heading reference with the words “California Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).

The California Consumer Privacy Act of 2018 (“CCPA”) permits California residents to request that we (1) disclose what Personal Information we collect, use, disclose and sell, and (2) delete your Personal Information. As indicated above, other states and jurisdictions have or may have similar laws.  To make such a request (whether further to CCPA or a similar law in another state or jurisdiction), please contact us at support@monsarrat.com with the words “Delete My Information” (or include the name of your state or jurisdiction) in the subject line of your email, or write to us at the address above and include a heading reference with the words “Delete My Information”, and include in your email or letter the request that we delete all of your Personal Information.  We will process such requests in accordance with applicable law. CCPA also offers an opt-out right with respect to the sale of personal data.  However, because we do not sell your personal data we do not offer such an opt-out mechanism. We will not discriminate against you if you exercise your CCPA rights.

Your Rights under the Colorado Privacy Act: Residents of Colorado are granted certain rights under the Colorado Privacy Act (CPA). These rights include the right to access personal data, to request correction of inaccurate personal data, and to delete personal data under certain circumstances. Moreover, such residents also have the right to receive a copy of their personal data in a portable and readily usable format. Additionally, residents of Colorado possess the right to opt-out of the processing of their personal data for targeted advertising purposes, the sale of personal data, or profiling that produces legal or similarly significant effects concerning you. Colorado citizens will not be discriminated against for exercising any of their CPA rights. To make such a request, please contact us at legal@monsarrat.com with the words “Colorado Privacy” in the subject line of your email, or write to us and include a heading reference with the words “Colorado Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed and/or any other information you may wish to review or requests you would like to make. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).

Your Rights Under the Virginia Consumer Data Protection Act: Virginia Law gives Virginia residents the right to access the personal data we have collected about them during the past twelve (12) months, including the categories of personal data, sources, business or commercial purpose, categories of third parties with whom we share personal data, and specific pieces of personal data we have collected about such residents. Virginia residents have the right to request the company to delete personal data we have collected, subject to certain exceptions in the VCDPA. They also have the right to opt out of our sale or sharing of their personal data and not be discriminated against for exercising any of their rights under the VCDPA. To make such a request, please contact us at legal@monsarrat.com with the words “Virginia Privacy” in the subject line of your email, or write to us and include a heading reference with the words “Virginia Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed and/or any other information you may wish to review or requests you would like to make. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).

Your Rights Under the Connecticut Data Privacy Act: Residents of Connecticut have the right to request the specific pieces of personal data we have collected about such person in the past twelve (12) months, including the categories of personal data, sources from which the personal data was collected, purposes for collecting or selling the personal data, and third parties with whom we share personal data. Residents have the right to request the deletion of their personal data and opt out of the sale or sharing of their personal data. You will not be discriminated against for exercising your privacy rights under the CTDPA. To make such a request, please contact us at legal@monsarrat.com with the words “Connecticut Privacy” in the subject line of your email, or write to us and include a heading reference with the words “Connecticut Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed and/or any other information you may wish to review or requests you would like to make. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).

Your Rights Under the Utah Consumer Privacy Act: Residents of Utah have the right to request access to their personal data, which includes information about the categories of personal data collected, sources of personal data, business or commercial purposes for collecting the personal data, categories of third parties with whom the data is shared, and specific pieces of personal data collected about them in the past twelve (12) months. Additionally, they have the right to request the deletion of their personal data and opt-out of the sale or sharing of their personal data. Exercising their privacy rights under the UCPA will not result in any discrimination against them. To make such a request, please contact us at legal@monsarrat.com with the words “Utah Privacy” in the subject line of your email, or write to us and include a heading reference with the words “Utah Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed and/or any other information you may wish to review or requests you would like to make. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).

To exercise any of these rights, or any similar rights based upon any other jurisdiction applicable to you, please contact us at legal@monsarrat.com. We may ask you to verify your identity before responding to your requests.

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to contact@monsarrat.com, and we will try to resolve your concerns.

Date of Last Update: August 8, 2023