Privacy Policy

Version 1.1
Updated: October 22, 2026

1. About this Privacy Policy

A Thinking Ape Entertainment Ltd. ("A Thinking Ape", "ATAE", "we", "us" or "our") respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, retain and protect personal information in connection with the game titled Island Hoppers (the "Game"), its official websites, player accounts, customer support and related services that we operate (together, the "Services").

It also explains the privacy choices and rights available to you.

This Privacy Policy applies when you play the Game, interact with its features, make purchases, contact our support team, visit our official Game websites or otherwise use the Services.

Some third-party services, such as app stores, payment providers and external social media platforms, process personal information under their own privacy policies. We explain below when we share information with those providers.

This Privacy Policy is provided for transparency purposes and does not form part of our Terms of Service. It does not, by itself, constitute consent to the collection, use or disclosure of personal information. Where consent is required by applicable law, we obtain it in the form required by that law, which may include express or implied consent, depending on the circumstances. Where separate affirmative consent is required, including for certain advertising, analytics, tracking technologies or marketing activities, we will request it separately.

2. Who is responsible for your personal information?

The controller responsible for the processing of personal information described in this Privacy Policy is:

A Thinking Ape Entertainment Ltd.
Suite 3500, 1133 Melville Street
The Stack, Vancouver, BC V6E 4E5
Canada

Privacy enquiries and requests: privacy@athinkingape.com
Player support: islandhoppersgeneral@athinkingape.com or through the in-game Support section.

3. What personal information do we collect?

The information we collect depends on how you access and use the Game, the features available to you, your device and platform, and your privacy choices.

Information you provide directly. This may include:

  1. Account information: player name, username, account details, contact information and preferences.
  2. Support information: information provided when you contact us, including correspondence, screenshots, attachments, purchase receipts and information needed to verify account ownership.
  3. Communications and User Content: messages, posts, reports and other content you submit using communication or community features available in the Game.
  4. Participation information: information submitted for surveys, competitions, promotional events or other optional activities.
  5. Privacy choices: your consent, withdrawal, opt-out and other privacy preferences, and information provided when exercising your rights.

We ask that you do not include sensitive personal information, payment-card credentials or unrelated personal information in support messages, chats or other free-text fields unless specifically requested and necessary.

Information we collect automatically. When you use the Game, we may collect:

  1. Game and Account data: account ID, player status, game progress, levels, achievements, virtual currency and item balances, inventory, entitlements and gameplay events.
  2. Technical information: IP address, device type, operating-system version, application version, device settings, language, network and connection information.
  3. Identifiers: Account, installation, session, authentication and device identifiers.
  4. Advertising identifiers may be processed when the relevant technology is enabled and permitted by applicable law and your choices.
  5. Usage and diagnostic information: session activity, feature interactions, server logs, application errors, crash reports, technical performance and troubleshooting information.
  6. Security information: login records, suspicious activity, anti-cheat signals, fraud indicators and information necessary to investigate abuse or protect the Game.
  7. Purchase information: order and transaction identifiers, purchased content, transaction date, price, currency, payment channel, refund status and chargeback information.
  8. General location information: approximate country or region inferred from your IP address or other relevant account and device settings.

The Game does not require precise GPS location for its ordinary operation. If we introduce a feature that requires precise location, we will provide the applicable notice and request any legally required permission before collecting it.

Information received from third parties. We may receive information from:

  1. App stores and platforms, such as Apple and Google, concerning your Account connection, purchases, refunds or entitlements.
  2. Authentication providers, where you choose to link an external account or use a supported sign-in method.
  3. Payment service providers, to confirm payments, refunds and transaction status. Analytics and advertising partners, where those services are enabled and permitted under applicable law and your privacy choices.
  4. Security and fraud-prevention providers, where necessary to detect and prevent abuse.
  5. Nexters or another previous operator, in connection with the transfer and continued operation of the Game.

We do not ordinarily receive complete payment-card credentials when purchases are processed by an app store or independent payment provider.

4. How and why do we use personal information?

The following table explains our principal processing activities, the information involved, our purposes and retention approach. The legal bases listed refer to the EU GDPR and UK GDPR, where applicable. In other jurisdictions, we process personal information according to the consent, reasonable-purpose, notice and other requirements established by the relevant laws.

Provide and operate the Game

Personal information
Account identifiers, game progress, inventory, settings, entitlements, game state and general region
Legal basis (EU/UK)
Performance of contract, Article 6(1)(b) GDPR
Retention
While needed to operate and maintain the account, subject to deletion and lawful retention requirements

Account creation, authentication and recovery

Personal information
Account and platform IDs, authentication linkages, login records, device and security information
Legal basis (EU/UK)
Contract; legitimate interests in account security
Retention
While the account is maintained, with limited additional retention where needed for security or claims

Purchases and virtual entitlements

Personal information
Purchase history, order IDs, amounts, currency, purchased items, refunds and chargebacks
Legal basis (EU/UK)
Contract; applicable legal obligations; legitimate interests in reconciliation and fraud prevention
Retention
Applicable accounting, tax, consumer protection, dispute and claims periods

Customer support

Personal information
Contact details, correspondence, account data, screenshots, attachments and transaction information relevant to the request
Legal basis (EU/UK)
Contract; legitimate interests in resolving requests and legal claims
Retention
Until the request is resolved and for a proportionate follow-up, security or claims period

Essential operation and diagnostics

Personal information
Technical logs, session and error data, IP address, app version, device and performance information
Legal basis (EU/UK)
Contract where necessary; legitimate interests in maintaining and securing the Services
Retention
As needed for troubleshooting, service operation and security, followed by deletion or de-identification

Security, fraud prevention and enforcement

Personal information
Account activity, login and device information, anti-cheat signals, transaction anomalies, reports and enforcement history
Legal basis (EU/UK)
Legitimate interests in preventing fraud, cheating and abuse; applicable legal obligations
Retention
While necessary to investigate, prevent and address relevant risks, disputes and legal claims

Communication and community features

Personal information
Player names, messages, posts, reports, related account information and moderation records
Legal basis (EU/UK)
Contract; legitimate interests in providing safe community functions; legal obligations where applicable
Retention
While necessary for the feature, moderation, safety, enforcement or legal purposes

Optional analytics and attribution

Personal information
Installation and advertising identifiers, selected gameplay or conversion events, device and app information, campaign and attribution data
Legal basis (EU/UK)
Consent where required; another lawful basis only where permitted by applicable law
Retention
According to the applicable consent, opt-out and documented measurement-retention periods

Advertising and advertising measurement

Personal information
Advertising identifiers, ad impressions, interactions, attribution events, technical data and applicable privacy signals
Legal basis (EU/UK)
Consent where required; otherwise the applicable lawful basis and opt-out rights
Retention
Until no longer necessary for the stated purpose, or as required by applicable consent and opt-out rules

Personalisation of Game features and offers, where enabled

Personal information
Account activity, progress, purchasing and engagement information, preferences and inferred interests
Legal basis (EU/UK)
Legitimate interests where lawful and proportionate; consent where required for tracking or profiling
Retention
While necessary for the disclosed personalisation purpose or until the relevant preference is withdrawn

Communications and marketing

Personal information
Contact details, Account information, language, communication preferences and delivery records
Legal basis (EU/UK)
Contract or legitimate interests for essential messages; consent or other permitted basis for marketing
Retention
While necessary for service communications or until the applicable marketing permission ends

Privacy choices and requests

Personal information
Consent records, opt-outs, objections, Account verification and rights-request records
Legal basis (EU/UK)
Legal obligations; legitimate interests in accountability and compliance
Retention
As necessary to fulfil and document requests and prevent prohibited reactivation of processing

Business transactions, operational continuity and data accuracy

Personal information
Relevant account, installation, gameplay, entitlement, transaction, support, security and technical records
Legal basis (EU/UK)
Legitimate interests in maintaining operational continuity and accurate records, where lawful; contract where necessary
Retention
As necessary for the transaction, transition or reconciliation and any continuing lawful purposes

Legal compliance and claims

Personal information
Information relevant to legal, regulatory, fraud, consumer, tax and accounting matters
Legal basis (EU/UK)
Applicable legal obligations; legitimate interests in establishing, exercising or defending claims
Retention
Applicable statutory periods, limitation periods, proceedings and legal holds

Where we rely on legitimate interests, these may include maintaining the security and reliability of the Game, improving its essential functionality, preventing cheating and fraud, protecting players, providing customer support and defending legal claims. We assess these interests against the rights and interests of affected individuals.

Where processing is necessary to provide a requested feature or fulfil a contractual or legal obligation, failure to provide the relevant information may mean that we cannot provide that feature, complete a purchase, recover an account or respond to the request.

Optional advertising, analytics and marketing are not required merely because you use the Game or accept its Terms of Service.

5. Player Account and Third-Party Login

The Game or individual features of a Game require a player profile or account (collectively "Account"). An Account is either automatically created when you first start a Game or when you provide the information (such as the player name) according to the registration form. The Game may allow you to use user account login details from other services (e.g. Facebook or Apple) to create an Account or link an existing Account to the relevant service. In detail:

5.1 Account Creation and processing of Account data. An Account is usually created when you start the Game for the first time. You might be required to enter certain user information (e.g. player name, email address, date of birth, age, password) to create an Account. Further information, such as an identification number ("ID"), the IP address of your device or further technical data identifying your device is automatically collected. Your Account is bound to your device by default. However, you can link your Account to third-party services such as Facebook, Google, or Apple by using the respective login features (see below). A Thinking Ape collects and processes the Account data in order to provide the Game and its features. We also use the Account data and further collected information to manage our relationship with you and provide you with our Account services. For example, we may also use your contact information (e.g. your e-mail address) to send you relevant communications in connection with your contract with us or your Account. To the extent that above services are provided within the framework of a contract with you, the basis of this data processing is the fulfilment of contractual obligations. In individual cases, the legal basis can be legitimate interest, whereby our legitimate interest is the management of our relationship with you.

5.2 FACEBOOK LOGIN. In the Game, we offer you the option of creating an Account or linking an existing Account by entering the login data of your Facebook user account (so-called "Facebook Login", formerly known as "Facebook Connect"). The Facebook Login is subject to your consent, which you can express by clicking on the corresponding button to connect to Facebook. The Facebook Login function is offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland ("Meta"). The login data of your Facebook account will be sent directly to Meta. We do not have access to your login data. After verification of your login data, Meta only informs us about the following data from your Facebook user account: the registered first and last name, date of birth, gender, email or phone number. Meta further checks which other Facebook users with whom you are connected on Facebook (so-called "friends") have already played the respective Game and provides us with this information. A Thinking Ape receives and uses the aforementioned data to set up your player Account in the Game. We also use the information about your friends on Facebook to enable you to invite a Facebook friend to a joint game session and to easily start this game session. However, we only process this information to the extent necessary to provide the respective social feature, i.e. for a joint gaming session. By using the Facebook Login function, Meta receives the information that you have created or linked an Account for the relevant Game and can link this information to your Facebook user account. Meta processes this information under its own responsibility; we have no influence on data processing at Meta. Meta may also transfer the information to its parent company in the USA, Meta Platforms, Inc. Since the parent company is certified under the EU-US Data Privacy Framework, such a data transfer could be based on the adequacy decision pursuant to Art. 45 GDPR. Information on how Meta handles your personal data can be found in Meta's privacy statement at: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
Data processing with the Facebook Login function is legally based on your consent which you give when calling up Facebook Login and subsequently entering your login data to your Facebook account. You can manage or revoke permissions through your Facebook account settings. Disconnecting Facebook does not automatically delete your Game Account or information that we are otherwise entitled or required to retain.

5.3 GOOGLE PLAY GAMES SERVICES. In the Game, we offer you the option to create or link your Account using your Google Play Games Services credentials. This service is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Upon your consent, Google shares with us your Google Play Games Services profile information, which may include your Gamer ID, profile image, and activity data. We do not have access to your Google account password. Google processes your data under its own responsibility. By using the Google Login or Google Play Games Services function, Google receives the information that you have created or linked an Account for the relevant Game and may link this information to your Google user account. Google processes this information under its own responsibility; we have no influence on data processing by Google. Further information on how Google handles your personal data can be found in Google’s privacy statement at: https://policies.google.com/privacy
Data processing with the Google Login function is legally based on your consent, which you give when calling up the Google Login and subsequently entering your login data. You can revoke your consent to data processing at any time with effect for the future by disconnecting your account or adjusting your settings in your Google account.

5.4 APPLE SIGN IN. In the Game, you have the option to create or link your Account using your Apple ID through the "Sign in with Apple" feature. This service is provided by Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA ("Apple"). Upon your consent, Apple shares with us your name and verified email address. If you choose to hide your email address, Apple generates a unique, random email address that forwards messages to your personal email. We do not have access to your Apple ID credentials. By using the Sign in with Apple function, Apple receives the information that you have created or linked an Account for the relevant Game and may link this information to your Apple ID. Apple processes this information under its own responsibility; we have no influence on data processing by Apple. Further information on how Apple handles your personal data can be found in Apple’s privacy statement at: https://www.apple.com/legal/privacy/en-ww/ Please find Apple's privacy policy regarding the Sign in Function at: https://www.apple.com/legal/privacy/data/en/sign-in-with-apple/ Data processing with the Apple Login function is legally based on your consent, which you give when calling up the Apple Login and subsequently entering your login data. You can revoke your consent to data processing at any time with effect for the future by disconnecting your account or adjusting your settings in your Apple account.

6. Analytics, advertising and tracking technologies

We use certain technologies to operate the Game, analyse its performance, measure advertising effectiveness and, where enabled, provide personalised experiences. These technologies may include software development kits (SDKs), cookies, local storage, account and device identifiers, server-side events and similar technologies. Depending on their purpose, these technologies may be provided by us or by third parties.

Essential Technologies. We use technologies necessary to operate, maintain and secure the Game, including to manage player sessions and accounts, save gameplay progress, deliver purchased content, detect technical failures, prevent fraud and unauthorised access, and implement privacy choices. These technologies are used without optional tracking consent only where permitted by applicable law.

Analytics and Performance Measurement. We may analyse gameplay activity, feature usage, technical performance, errors and other operational information to understand and improve the Game and our Services. Certain analytics may be carried out on the basis of our legitimate interests in maintaining, improving and securing the Game, where permitted by law. Where analytics involve non-essential tracking technologies, third-party SDKs or other processing requiring consent, we obtain the necessary consent before activating those technologies or carrying out the relevant processing.

Measurement Accuracy and Operational Transitions. We may process account and installation identifiers, historical gameplay and transaction records, and related technical information to maintain the accuracy and integrity of our operational records, including following changes to the operator of the Game or our analytics and measurement providers. This may include distinguishing existing players from new installations, preventing duplicate records, reconciling historical data and maintaining accurate reporting. Where permitted by applicable law, we may engage service providers for these purposes under appropriate contractual and technical safeguards. Such processing does not independently authorise optional advertising tracking or other activities requiring separate consent.

Advertising and Attribution. We may use advertising and mobile measurement partners to understand how players discover the Game, measure advertising campaigns, attribute installations and in-game events to advertising activities, and assess advertising effectiveness. Depending on the technologies used, this may involve advertising or installation identifiers, device and application information, campaign details, advertising interactions, and selected gameplay, purchase or conversion events. Where applicable law requires consent for tracking, device access, identifier disclosure or related processing, we obtain that consent before carrying out the relevant activities.

Personalised Advertising. Where available and permitted by applicable law, we may use information about your activity, interests or interactions with advertisements to deliver or measure personalised advertising. Advertising partners may process information on our behalf or as independent controllers and may, where legally permitted, combine information with data obtained from other services. Such activities are subject to applicable consent requirements, opt-out rights and age-related restrictions.

Personalised Game Content and Offers. We may use information about your gameplay, progress, engagement, purchases and preferences to personalise Game features, recommendations, content and in-game offers. Where lawful and proportionate, we may rely on our legitimate interests for such first-party personalisation. Where additional consent or disclosure is required, including for certain tracking, profiling or personalised pricing activities, we will comply with those requirements.

Your Privacy Choices. Where required by applicable law, you can accept, reject or withdraw consent for non-essential analytics, advertising and tracking without losing access to the core Game. You can manage available preferences through the Game.
You may also manage certain device-level permissions and preferences, including Apple's App Tracking Transparency permission and Android advertising settings. These controls operate alongside, and do not replace, other applicable privacy rights. Where required by law, we also provide options to opt out of the sale or sharing of personal information or targeted advertising, including through recognised opt-out preference signals where applicable.

Withdrawing consent does not affect processing lawfully carried out before withdrawal. We will stop the affected consent-based processing and communicate updated preferences to relevant providers as required by applicable law.

Additional Information. For further details about active analytics, advertising and tracking providers, including their purposes and applicable privacy policies, see: our list of service providers

7. Player communications, moderation and security

Where the Game provides communication or community features, information you submit may be visible to other players according to the feature's settings and functionality. We process relevant communications and associated account information to deliver those features, investigate reports, prevent cheating, fraud, harassment and other prohibited conduct, and enforce the Game's rules. We may use automated filters, fraud detection systems and other tools to identify potentially harmful or prohibited activity. Authorised personnel may review relevant information where necessary for moderation, investigations, appeals, security or legal compliance. Access to private communications is subject to appropriate purpose-based restrictions and access controls. We do not treat private player communications as a general-purpose advertising or marketing data source. We may retain relevant evidence of serious misconduct, fraud or security incidents where necessary to prevent recurring abuse, respond to disputes, establish or defend legal claims, or comply with legal obligations.

8. Direct Marketing

8.1 In the Game, you can register for our newsletter to receive news about the Game, promo codes and other information related to our Game. Details about the content of each newsletter are specified in the individual registration form. In order to register you and send you the newsletter, we need your valid email address. To verify that you are the owner of the email address provided and that you would indeed like to receive information from us.. Once you have successfully signed up for the newsletter service, your registration will be activated and the chosen newsletter will be sent out. We use your email address to send you the newsletter.

Please note that we also evaluate the opening, unsubscription and click rates in connection with your use of the newsletter and use these findings to improve the newsletter. For this evaluation, the newsletter emails sent contain so-called tracking pixels, which help us to recognise when recipients open a newsletter email, and so-called tracking links, which help us to recognise when recipients click on a link contained in our newsletter. This information is used to create an open and click rate, which we can use to statistically evaluate the percentage of recipients who opened a newsletter sent by us. We can also see which recipients opened our newsletter and which did not. By evaluating this data, we can draw conclusions about the recipients' interest in our newsletter content and improve and develop the newsletter accordingly. We use Mailchimp, operated by Rocket Science Group LLC to dispatch the newsletter and evaluate its usage. The legal basis for data processing in the context of the newsletter is your consent. You can unsubscribe from the e-mail newsletters and revoke your consent at any time with effect for the future. To unsubscribe or revoke you only have to send an e-mail to islandhoppersgeneral@athinkingape.com or click the unsubscribe link contained in each newsletter.

9. When do we share personal information?

We disclose personal information only where necessary for the purposes described in this Policy, where permitted or required by law, or in accordance with your applicable choices. Recipients may include:

  1. Service providers and processors.
    - Providers of hosting, cloud infrastructure, database services, authentication, security, fraud prevention, diagnostics, communications, customer support and other operational services.
    - App stores, payment and authentication providers.
    - Providers involved in installing or accessing the Game, linking accounts, processing purchases, maintaining entitlements and administering refunds.
    - Advertising, analytics and measurement partners.
    - Providers involved in optional advertising, campaign measurement, attribution and analytics, subject to applicable consent and opt-out requirements.
    - Other players and the public. Information you choose to display through public profiles, rankings, leaderboards or community functions may be visible to other players or the public, depending on the feature.
    - Affiliates and professional advisers. Our corporate group, lawyers, auditors, accountants and other advisers, to the extent necessary for legitimate operational, administrative, transaction or legal purposes.
    - Business-transaction recipients. Prospective or actual purchasers, successors, investors or other parties involved in a merger, acquisition, reorganisation, financing or transfer of the Game or relevant business assets, subject to applicable safeguards and laws.
    - Authorities and legal recipients. Courts, regulators, law-enforcement agencies and other recipients where disclosure is required by law or otherwise lawful and necessary to protect rights, safety or legal claims.

Depending on the services provided and the applicable arrangements, these recipients may process personal information on our behalf or under their own responsibility. Where a recipient processes personal information on our behalf, we implement appropriate contractual safeguards as required by applicable law.

Certain third parties, including app stores, payment providers, authentication services and advertising partners, may process personal information as independent controllers. Their processing may also be governed by their own privacy notices.

We may also share personal information with our affiliates, professional advisers, prospective or actual business transaction counterparties, and competent authorities where permitted or required by applicable law and for the purposes described in this Policy.

Our main service providers are currently: Amazon Web Services, Google Cloud, Zendesk, and Tableau .

10. International transfers of personal information

A Thinking Ape is based in Canada. Personal information may be processed in Canada and in other countries where our service providers, affiliates or authorised partners operate, including the United States where applicable. These countries may have privacy laws that differ from those in your country. Where personal information protected by the EU GDPR is transferred from the European Economic Area to a Canadian recipient covered by the European Commission's adequacy decision for Canadian commercial organisations, the transfer may rely on that decision. Where an international transfer is not covered by an applicable adequacy decision, we implement an appropriate transfer mechanism where required by law. Depending on the circumstances, this may include the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, or another mechanism permitted under applicable law. Transfers to appropriately certified US recipients may rely on an applicable EU-US Data Privacy Framework or UK Extension adequacy arrangement, where its requirements are met. We assess the applicable safeguards and implement supplementary protections where required. You may request further information about the relevant transfer mechanism and how to obtain a copy of the applicable safeguards by contacting us.

11. How long do we retain personal information?

We retain personal information only for as long as reasonably necessary for the purposes for which it is processed, unless a longer period is required or permitted by applicable law. The principal retention periods or criteria are described in Section 4.

When determining the appropriate period, we consider:

  1. whether the account remains active;
  2. the purpose for which information was collected;
  3. whether the information is needed to maintain purchased entitlements or Game progress;
  4. the sensitivity and volume of the information; security, fraud and abuse risks;
  5. applicable tax, accounting, consumer protection and other legal requirements;
  6. ongoing complaints, disputes, investigations or legal claims;
  7. applicable platform requirements; and the status of deletion requests, privacy choices and legal holds.

If you delete your Account, we will delete or de-identify personal information that is no longer necessary, subject to applicable legal and operational exceptions. Where permitted by applicable law, we may retain limited information following Account deletion to prevent fraud, cheating or repeated violations, administer disputes, maintain necessary records of previous enforcement actions, comply with legal obligations, and establish, exercise or defend legal claims. Such retention is subject to applicable necessity, proportionality and storage limitation requirements. Data in technical backups may remain until the relevant backup is overwritten or deleted under our documented backup-retention cycle. Such data is protected from ordinary use, and applicable deletion or restriction instructions are maintained where necessary. Where personal information is no longer needed, we delete, anonymise or otherwise dispose of it securely.

12. Your privacy rights and choices

Depending on your country or state of residence and the laws that apply, you may have the following rights:

  1. Access and information. Request confirmation of whether we process your personal information and receive information about that processing or a copy of the relevant data.
  2. Correction. Request correction of inaccurate or incomplete personal information.
  3. Deletion. Request deletion of personal information where the applicable legal conditions are met.
  4. Restriction. Request that certain processing be restricted or suspended where permitted by law.
  5. Portability. Request a copy of eligible information in a structured, commonly used and machine-readable format, or request transfer to another provider where legally required and technically feasible.
  6. Objection. Object to certain processing, including processing based on legitimate interests where the relevant law provides that right.
  7. Withdrawal of consent. Withdraw consent for an optional activity at any time.
  8. Marketing opt-out. Stop receiving marketing communications by using the unsubscribe link or applicable communication settings.
  1. Automated decision-making rights. Exercise rights relating to decisions based solely on automated processing that produce legal or similarly significant effects, where applicable.
  1. Complaint. Lodge a complaint with a competent privacy or data protection authority.

How to submit a request

You can submit a privacy request, including the data and account deletion request:

We may request proportionate information to verify your identity or your authority to act for another person. We will not request unnecessary identity documents where the request can be verified using existing account information.

If you request deletion of information necessary to operate your Account, this may result in loss of access to the Game, progress or entitlements, subject to applicable legal rights.

We may decline or limit a request where an applicable legal exception allows or requires this, including where information is necessary for compliance, security, fraud prevention, legal claims or the protection of other individuals' rights.

We respond within the periods required by applicable law and explain any refusal or limitation where legally required.

Where applicable law gives you the right to appeal a decision on your privacy request, you may submit an appeal using the contact details above and identifying it as a "Privacy Appeal". We will review the appeal and provide a response, including information about further available remedies where required by law.

Exercising a privacy right will not result in unlawful discrimination or retaliation.

13. Additional rights for EU and EEA residents

If the EU GDPR applies to our processing of your personal data, you may exercise the rights provided by Articles 15 to 22 GDPR, subject to their applicable conditions and exceptions. These include access, rectification, erasure, restriction, portability, objection and rights relating to certain automated decisions.

Where we rely on legitimate interests under Article 6(1)(f), you may object on grounds relating to your particular situation. We will cease the relevant processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for legal claims.

You may object at any time to processing of your personal data for direct marketing, including associated profiling. We will stop that processing following a valid objection.

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of earlier consent-based processing. You may lodge a complaint with the competent supervisory authority, including the authority in the EU Member State of your habitual residence, place of work or place of an alleged infringement.

14. Children's privacy

The Game and Services are not intended to be used by a child in a manner prohibited by applicable law. Where applicable law requires parental or guardian authorisation for a child's use of the Game or for a particular processing activity, that authorisation must be obtained through the applicable process. We minimise information relating to children and do not use identified child accounts for behavioural advertising, look-alike audiences or optional profiling that applicable law prohibits. If COPPA applies, we will provide the notices and obtain the verifiable parental consent required by it before collecting, using or disclosing a child's personal data, except where an applicable exception permits otherwise. A parent or guardian who believes that a child's information has been processed contrary to applicable law may contact us through Support or at privacy@athinkingape.com to request review, correction, restriction or deletion.

15. Automated processing

We may use automated systems to analyse technical, gameplay and transaction information to identify potential cheating, fraud, security incidents, prohibited conduct or technical problems. These systems may generate alerts, classifications or recommendations for investigation or enforcement. We may also use automated processing to personalise Game experiences or offers where enabled. Where automated decision-making gives rise to additional rights or obligations under applicable law, we will provide the required information and safeguards, including opportunities to request human intervention or review, obtain an explanation or contest a decision, where legally required.

16. How do we protect personal information?

We implement technical, organisational and administrative safeguards appropriate to the nature, sensitivity and risks of the personal information we process. These may include access restrictions, authentication, encryption, logging, monitoring, security testing, staff confidentiality obligations, incident-response processes and contractual safeguards for service providers. We review and update security measures as appropriate. No system or method of transmission is entirely free from risk. If you believe your Account has been compromised or that your personal information is at risk, please contact Support.

17. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in the Game, our processing activities, technology, legal requirements or business operations. We will publish the updated version and its effective date.

Where required by applicable law, we will provide additional notice of material changes or obtain consent before implementing changes to our processing activities that require such notice or consent.

18. Contact us

For privacy questions, requests or complaints, please contact:

A Thinking Ape Entertainment Ltd.
Suite 3500, 1133 Melville Street
The Stack, Vancouver, BC V6E 4E5
Canada

Privacy: privacy@athinkingape.com
Game Support: islandhoppersgeneral@athinkingape.com

You may also contact us using the in-game Support function.

This Privacy Policy is available in English and may be provided in other languages where required by applicable law. Where local law provides otherwise, the English version does not override the version or language rights protected by that law.