Privacy Policy

1. Privacy Policy Overview

Arlene, Inc. and its subsidiaries and affiliates (collectively “Arlene”) offer a variety of products, services, and websites for extended reality Developers and users that will be referred to in this policy as the “Service” or “Services.” Because we would like to avoid excessive formality and make this information easy to understand, the policy refers to Arlene as “we” or “us” and to the reader as “you.” When we say “device,” we mean any device, including desktop, laptop, PC or Mac computers, smartphones, tablets, or any other device that is used to access or interact with the Service. When we say “Developer,” we mean a third party that develops and/or distributes an experience or other app made with Arlene software and/or a game using Arlene Services. By using the Service, you agree to this Privacy Policy and understand that we may transfer your data outside of the European Economic Area (EEA).

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

This Privacy Policy governs our information practices for the Service, which includes any websites, where a link to this policy is provided. It describes how

we collect, use, share, and protect information from Developers, players, ad recipients, or people browsing or using our sites (collectively “Users”) when Users access or interact with or use our Service. This Privacy Policy also applies to the personal data we collect offline, such as when you call us or interact with Arlene in person, such as at an industry event or at a place of business. This includes when Users:

Visit Arlene websites
License and download Arlene’s extended reality and app development software (“Arlene Software”)

We receive information about Users, their devices, locations, and interactions with the Service primarily in two ways:

Actively: When Users actively provide us with information. For example, when a User creates an account with Arlene, he or she will type in a name, username, and email address and may be required to provide a date of birth or other information.

Passively: When our systems automatically collect information about browsers, devices, and certain activity within the Service. For example, when Users access games that employ Arlene Analytics, our systems (with assistance from the Developers who want our help to analyze the use of their experiences) may automatically collect a variety of information from User devices and/or User game activity, including device name, device characteristics, and unique identifiers (e.g., Apple IDFA and Google Android Ad ID).

2. Information We Collect (Depending on the Product or Service)

Information that you or others actively provide, including:

Name
Age or date of birth
Gender
Email address
Physical or mailing address
Phone number
Name and contact information for a business or organization Password(s) that Users create to access parts of the Service Billing or financial account information and tax or government IDs:
- When Users provide payment (e.g. credit card information, billing address, etc.) information to make a purchase, that information is sent to payment processors who assist Arlene. Arlene’s payment systems are not designed to store credit card numbers.
- Social network information: When you log in to our Services with a social network account, you may have the option of sharing information such as the name you use on that network and your friends list or other information that the third party social network chooses to share with Arlene.
Company information including but not limited to company name, work, address, and job title.
Location information:
- Users can actively provide specific location information in certain account registration processes or when providing payment information, such as a billing address.
- Users can choose to share the specific location of their device by permitting games and apps, including those that use Arlene Analytics, to access it through the GPS functionality on their device.

Information that is passively collected by Arlene (often automatically), including:

Device Information: including various unique identifiers, such as IDFA, Android Ad ID, IDFV, MAC address, when, for example:
- You access experiences provided by Developers that are developed with Arlene Software;
- You access games in which the Developer employs Arlene Analytics or deltaDNA to understand the use of their games and improve the player experience
- You receive ads delivered by Arlene Ads;
- Location information: Our systems (like most used on the web) automatically collect an IP address when Users access the Service. IP addresses can be used to learn about the general location (e.g. city, state and country) of the User’s point of access to the web.
Log information: When you access our website(s), Services or products that use an aspect of our Service, we may log a variety of technical information (“Log Info”), including:
- IP address
- Device information, including device name and IDs, hardware model, operating system and version, and mobile network information
- Browser information
- Cookie information
- Login data
- Language preferences
- Linking information and click stream data
- Date/time of access and time zone setting
- Search engine(s) and keywords used to find our website(s); Pages viewed within our website(s) and/ or website log files; Requested page(s)
- Referring page(s)
User device information: When you use an experience built with Arlene Software, Arlene may collect some or all of the following information:
- Unique device identifier generated from the device
- An advertising ID, such as the Apple IDFA or the Android Ad ID;
- IP address
- Device manufacturer and model
- The operating system and version running on your system or device
- Browser type
- Language
- The make of the CPU, and number of CPUs present
- The graphics card information, such as type, vendor and driver name, version and graphics API
- Amount of system and video RAM present
- Current screen resolution
- Operating system identifier (e.g., Mac, Windows, etc.)
- A checksum of all the data that gets sent to verify that it did transmit correctly.
Developer Software information: When you use Arlene Software to develop experiences and apps, we will collect IP address, Arlene ID, organization ID, project ID, session ID, time stamps (associated with events), Arlene Software serial and version number, Arlene Software Revision ID, build target, OS platform and version, asset count (approximate number of assets in a folder), session duration, and active duration (this differs from session duration as a session may not time out). We collect this information and connect it to event information for the purpose of core business metrics analysis. You cannot opt-out of core business metric analytics as such analytics are strictly necessary for us to run the services.
We also collect aggregate metrics that we use for usage analytics. You can opt-out of usage analytics in “Edit Your Privacy Settings” in the Privacy section under “My Account”.
When you use Arlene Software, it may automatically make Internet connections to check for updates, validate your license keys, and provide us with aggregated usage statistics. We may employ third-party analytics services to collect and analyze Developers’ use of the Arlene Software.

Unless we request it, we ask that you not send us, and you not disclose, any special category data or criminal offense data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through the Arlene website, the Services or otherwise to us.

3. How We Use the Information We Collect or Receive

A. Use at a Glance

We primarily use the information we collect to provide, administer, operate and improve our Services. We may use your information for the following purposes:

To create, administer and troubleshoot accounts, Services we provide; To credit or accept payments
To provide technical support and respond to inquiries
To prevent fraud, enforce the relevant terms of service or licenses, and protect Users
To analyze the use of the relevant ad, site, experience, product, or software; test changes and improvements; to personalize your experiences, and; to identify and suggest connections with other Users
To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of website(s), products and services that Arlene and Developers provide
To perform analytics and research on our core business metrics, and to take action on the results of such analysis
To create and share statistics and reports regarding aggregate usage of Arlene-powered apps
To enable user-to-user communications
To link to or combine with other information we have gathered
To deliver and target advertising, including personalized ads
To inform Users of new products and services, including promotional offers
To contact you with information that we believe will be of interest to you. As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

B. Comprehensive List

Below we list how we and our service providers use Personal Information for legitimate business purposes more comprehensively and inclusive of our legal basis for such collection and use as required by laws of certain jurisdictions where we operate including:

Providing the functionality of the Services and fulfilling your requests.

To provide the website(s) and Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service, including troubleshooting and service restoration.

To analyze and take action on the analysis of our core business metrics. To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services. To complete your transactions (including financial) and provide you with related customer service.

To send administrative information to you, such as changes to our terms, conditions and policies.
To allow you to send messages to another person if you choose to do so.

We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, when we have your consent (e.g., when you are requesting for us to respond to you), and/ or when necessary for our

legitimate interests (e.g., to respond to inquiries from customers and potential customers, for license enforcement and prevention of software piracy, to inform decisions around service offerings, and for operational improvements).

Providing you with our newsletter and/or other marketing materials and facilitating social sharing

To send you marketing related emails, with information about our services, new products and other news about our company.
To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

Analysis of Personal Information for business reporting and providing personalized services.

To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our website(s) and Services.
To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
To better understand your preferences so that we can deliver content via our website(s) and Services that we believe will be relevant and interesting to you.

We will perform analyses based on our legitimate interest. We will provide personalized services either with your consent or because we have a legitimate interest.

Accomplishing our business purposes.

For data analysis and testing, for example, to improve the efficiency of our website(s) and Services;
For system maintenance;
For reporting and hosting of data;

For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
For fraud and security purposes, for example, monitoring to detect and prevent cyberattacks or attempts to commit identity theft;

For the prevention of criminal activity or harm to users of our Services; For developing new products and services;
For enhancing, improving, or modifying our current website(s), products and services and/or assisting our developers with this activity;

For identifying usage trends, for example, understanding which parts of our website(s) and Services are of most interest to users;
For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users or our publisher’s and other advertising customer’s users; and

For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users or assisting our developers with this activity within their business so we can focus our and their energies and resources on meeting our users’ interests;

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have your consent or a legitimate interest.

Aggregating and/or anonymizing Personal Information.

We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

C. To allow us to disclose your information to the extent permitted by law, in the situations described more fully below

Arlene Technologies, Inc. is the party responsible for the management of the jointly-used Personal Information.

To our third-party service providers, to facilitate services they provide to us.

These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery marketing, mailing, surveys, auditing, and other services

To third parties, to permit them to send you marketing communications, consistent with your choices.
To third-party sponsors of sweepstakes, contests, and similar promotions.

By using the Services, you may elect to disclose Personal Information
On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Through your social sharing activity. When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy

Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

To comply with applicable law and regulations. This can include laws outside your country of residence.

To cooperate with public and government authorities. To respond to a request or to provide information we believe is important. These can include authorities outside your country of residence.
To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders or provide information we believe is important.

For other legal reasons. For example, to enforce our terms and conditions or licenses; and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.

4. Sharing Information

How we might share the information we collect or receive

Our affiliates located all over the world for the purposes described in this Privacy Policy on a need to know basis.
Third-party service providers: We provide User information to other companies that perform Services on Arlene’s behalf. For example, we
may employ service providers to process payments; host or store our data; deliver email messages; provide legal or other guidance; or analyze data.
Sale or merger: In the event that Arlene explores or undergoes a business transition, such as a merger, acquisition by another company, transfer of control, or sale of all or a portion of its assets, we may share or transfer all of your information, including personal information. Advertising:

Arlene Ads: We may utilize the data collected from Developers’ apps to place personalized ads in Developers’ apps and elsewhere. This usage will permit other parties, such as publishers and attribution companies, to learn about the devices that received, viewed or interacted with ads.
Third-party products and services: We may permit advertisers and their agents to use cookies or related technologies within the Service to store information on or read information from your browser or device so that they can optimize their advertising campaigns, including to frequency cap and deliver targeted ads.

With your consent: We may share your information for other purposes if (i) you direct us to do so or (ii) you consent to such sharing. De-identified and/or aggregated information: Some of the information we collect does not directly identify you or your device. We may modify other information that can identify you or your device to limit or prevent such identification by de-identifying it or aggregating it. We can share de-identified and/or aggregated information with any third party without restriction and use it for any purpose.

As may be required if we transfer your personal information, we will ensure it is protected in a manner that is consistent with how your personal information will be protected by us in the country of collection, either by contractual or other means to provide a comparable level of protection while the information is processed by a third party.

5. Our Policies Concerning Children

Our Services are intended for general audiences. Arlene does not knowingly collect any personal information from children. Beginning in January 2020, Arlene’s ads service may collect a certain age range or age band information to confirm that we comply with Applicable Data Protection laws.

If any party becomes aware that a child under the age of 13, or under the age of 16 for those parties in the European Economic Area, has provided us with personal information in contravention of our policies, they should contact us at sales@arlene.io.
Some third parties, such as platform providers like the iTunes Store or Google Play, may provide age-based ratings on some of the apps created by Developers. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.

6. Accessing/Updating/Deleting Your Information

We provide Users with a variety of ways to access and update their information (described below). For those with Arlene accounts described below, please send any requests or questions to sales@arlene.io.

Arlene Software

Developers: Email sales@arlene.io. You can request that your account be deleted; however, certain financial recordkeeping information may be maintained in our systems because we have a legitimate legal and financial interest in maintaining such records.

Arlene Ads

Publishers and Advertisers: Log in to your account and navigate to the Settings page where you can view and update your information. You can request that your account be deleted; however, certain financial recordkeeping information may be maintained in our systems because we have a legitimate legal and financial interest in maintaining such records.

For services not listed

Please email sales@arlene.io to request access to or update your information. You can request that your account be deleted by emailing sales@arlene.io; however, certain financial recordkeeping information may be maintained in our
systems because we have a legitimate legal and financial interest in maintaining such records.

7. Your Choices About Arlene’s Collection and Use of Your Information

You always have the option to refrain from using the Service or to discontinue using the Service if you do not want information collected about you.

You can choose to use the Service in a manner that limits the data we collect. For example, in Arlene’s Connect service you can choose not to publicly share your profile.

You can access and update your information as described in the section “7. Accessing/Updating Your Information.”

You can opt out of communications like email, by following the instructions in any marketing message you receive. However,

We reserve the right to send a message confirming your opt-out, whether it applies to email or SMS messages; and
Users who opt-out of marketing messages may still receive administrative, relationship, or transactional messages (e.g., we might send a notice about changes to our Terms of Service or changes to the functionality of a product or Service).

Please note that if you are not in the European Economic Area (EEA) or California, your app publisher may have chosen to only apply the opt-out to those players in those jurisdictions where applicable privacy laws require choice. If that is the case, you may opt-out of all tracking by following the instructions in our Advertising Choices section.

Analytics opt-out: Arlene Analytics offers an opt-out to Users of Developer apps to the extent the data collected may be used for targeting purposes and assisting Arlene Ads in delivery of its Services. If you do not want your information collected by Arlene Analytics for other purposes described herein, such as crash reporting or helping you save your place in the game, you may have to stop using the game or application utilizing Arlene Analytics.
We use Google Analytics to understand how our sites are used and to improve experiences within the Service. If you want to know more about how Google Analytics works or to exercise choice in regard to the data collected by it, please visit https://www.google.com/policies/privacy/partners/. In order to control the collection of data for analytical purposes by Google, you can install the Google Analytics Opt-out Browser Add-On. Please note that we can use our own logging and tracking to understand the use of our sites that do not make use of Google Analytics, and your use of their browser add-on will not impact that tracking.

8. Transfers out of Country of Collection

Arlene has implemented and maintains a framework consistent with applicable law for transfers of data outside of the country of collection, including for transfers out of the EEA.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting sales@arlene.io.

9. Retention

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

10. Safeguards

We employ a variety of measures to safeguard the collection, transmission, and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process, and store, and the current state of technology. Please note that no system can be guaranteed to be 100% secure. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee or warrant the security of the information you share with us and we cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your information. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a
password with anyone. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Changes to This Privacy Policy

We reserve the right to change our practices and this policy at any time. We may also send an email or provide notice within some or all of our offerings when this policy changes. We encourage you to check this page regularly so that you know what our current practices are.

12. Privacy Rights

Please note that Arlene has placed a new California Notice of Rights on its website to explain how California residents may exercise their privacy rights under the California Consumer Privacy Act. This notice is incorporated into this policy. Generally, under this new law, California residents have
Sharing with third parties for direct marketing purposes: California residents have the right to request the identity of any third parties to whom the resident’s personal information was shared, if such sharing was to enable the third party’s direct marketing efforts. If you are a California resident and wish to make such a request, please submit your request to sales@arlene.io OR to opt-out of having your personal
information shared with third parties for their direct marketing purposes, please email us at sales@arlene.io.

A right to transparent notice about the collection of your data;
A right to know what personal information Arlene holds about you, including where we obtain it and the categories of third parties with whom we share it,
A right to request deletion of personal information in certain circumstances;
A right to opt-out of sales of personal information;
An ability to appoint a third party representative to assist you with exercising your rights and,
A right not to be discriminated against for exercising your rights.
Please note Arlene does not discriminate in its provision of services to you based on exercising your rights.
Your requests to delete data is limited to data that Arlene is not allowed to retain under the CCPA. Arlene may retain data for certain purposes, including completing transactions for you or reasonably related to completing transactions for you, detecting security incidents, illegal activity and fraud, maintaining our systems, complying with applicable law and legal obligations, engaging in public or peer reviewed research provided we comply with applicable ethics and privacy laws related to such research, or enabling solely internal purposes such as financial recordkeeping.
You may ask a third party representative to assist you in exercising your rights. Third parties may write to sales@arlene.io to provide documentation of their right to act on your behalf. If you are a game player, we will not have a way to locate records about your outside of an app using Arlene’s software, but you may direct your reports to be sent to your representative once you have verified your identity inside of the app. Arlene account holders may also send data reports obtained through your account directly to your representative. You need only to provide their email or mailing address instead of your own when ordering. For third party representatives writing in on behalf of Arlene account holders, please provide the name and any signed documentation you may have to act on behalf of the account holder, or you may ask the account holder to write to us from their account email to provide us permission to transact with you directly. Arlene reserves the right to take reasonable steps to verify the authenticity of identities and authorizations in compliance with applicable laws prior to making any disclosures.
How we respond to “Do Not Track” signals: We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide informatio how to prevent the delivery of targeted ads, and information in this policy about how to prevent Google Analytics and Twitter from collecting information. We do not, however, recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not

Track standards, implementations, and solutions. To learn more about Do Not Track signals, you can visit allaboutdnt.com.

If you are a European Union resident, the General Data Protection Regulation provides certain rights to you with respect to your personal data. Where Arlene is a data controller, you have the following rights:

Right to Access – You have the right to request Arlene provide you with a copy of your personal data.
Right to Rectification (Correction) – You have the right to request Arlene to correct any information about you that you believe is incorrect. You also have the right to request Arlene to complete information about you that you believe is incorrect.
Right to Erasure (Deletion) – You have the right to request Arlene to erase your personal data, under certain conditions.
Right to Restrict Processing – You have the right to request Arlene to restrict the processing of your personal data, under certain conditions. Right to Object to Processing – You have the right to object to Arlene’s processing of your personal data, under certain conditions.
Right to Data Portability – You have the right to request Arlene to transfer your personal data that we have collected to another organization, or directly to you, under certain conditions.

The Canadian Personal Information Protection and Electronic Documents Act provides certain rights with respect to your personal data, such as:

The Brazilian General Data Protection Act provides you the right to:

Confirm Arlene’s processing of your data;
Access your data;
Correct your incomplete, inaccurate, or outdated data;
Request anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the Brazilian General Data Protection Act;
Port your data to other service providers or suppliers of products;
Delete your personal data when processed with your consent;
Obtain information on the public and private entities with whom Arlene shared your data;
Obtain information on the possibility of not providing consent and on the consequences of the denial;
Revoke your consent to the processing of your data when we seek your consent; and
Lodge complaints before data protection authorities.

The Israel Protection of Privacy Law 5741-1981:

Any information provided by you is on a voluntary basis with no legal requirement to do so, but if you refuse to provide such information we may not be able to provide you with the Services. According to the Protection of Privacy Law, each person is entitled to inspect, either himself or through a representative authorized by him in writing or his guardian, any information about him kept in a database.

To exercise the above rights, email sales@arlene.io (or contact us as indicated in the ‘Contact Us’ section below). In some cases a Arlene customer, such as a game developer, may be the controller of your data and Arlene only a Processor. In this case, Arlene will direct you to its customer, and Arlene will support its customers in responding to requests as required by law.

In addition, where our processing activities in respect of your Personal Data are subject to the GDPR, you may lodge a complaint with a European Union supervisory authority. If you do have a complaint, we would appreciate the chance to deal with your concerns before approaching your supervisory body, so please contact us at sales@arlene.io.

13. Links to Sites and Service Operated by Others

The Arlene Service may contain links to other sites, applications, and services. Because Arlene does not operate those other sites, applications, and services, we cannot take responsibility for the privacy practices of the
entities that operate them. We recommend that you consistently check privacy policies to understand an operator’s practices. As a reminder, this policy describes Arlene’s practices.

14. Contact Us:

sales@arlene.io
Arlene, Inc., 249 Smith Street #129, Brooklyn, NY 11231 (United States contact)

15. Cookie Policy

What are cookies?
Cookies are pieces of data that sites and services you use or visit can set on your browser or device and they can typically be read on future visits to learn more about the User and to personalize an experience, including the ads that are displayed to the User. “Cookies” is also a term that may be used to refer to a range of technologies that help an operator identify Users and devices, which in turn can help personalize an experience, prevent fraud, store preferences, and speed up delivery of content.
To update your cookie preferences, please select “Cookie Settings” at the bottom of the webpage.

16. Arlene Ads Privacy Features and Third Party Partners in Providing Advertising

Privacy Features

If Arlene delivers personalized advertising through its ad network, Arlene will provide notice and information about how you may be able to opt-out of such personalized advertisements. Please note that the limitations available to you are determined by the laws within your jurisdiction and the tools the developer of your game chooses to implement.

Developer Advertising Using Other Ad Networks

Developers may use other third-party advertising networks, and Arlene’s choice features within its ad units only apply to ads delivered in the Arlene network.

Please note that the Developer of the app showing Arlene Ads may have limited providing certain identifying information, including your device advertising ID, about you to our third-party partners advertising goods and services (non-game advertisements) with Arlene. If that is the case, you will see an affirmative statement to that effect when you view the information inside of an Arlene Ad through the “i” button or Data privacy icon inside of your app. You may still see ads from the partners listed below, but they will not be based on your personal data. Additionally, you may have opted-out of profiling in Arlene’s ad network within an Arlene Ad for your app, and we will
only serve contextual ads from ourselves and these partners within your app. For all others, please review the following information:

Third Party Ad Network Partners

The following third-party partners may receive an ad request from Arlene containing your advertising ID, IP address, and the name of the app/game in which you will see the ad. This list may be updated from time to time. These partners use this information build your profile and personalize your ad experience to serve future ads you may see on the internet as well as inside the Arlene ad network. The privacy policies linked below provide you information around the data that they have from all sources, including Arlene, and your rights to delete or remove data.

17. Other Useful Information

Some of Arlene’s product features require access to your camera. While using these features we ask that you be aware of your surroundings and be considerate of others. Use of these features may result in cached images being saved to your device. In certain products, we may save your images to our cloud servers. You will be notified at the time of access if the images are being saved to our servers. Please keep your security features on your device up to date and securely dispose of your device when you change devices by clearing this information.

18. Biometric Information

Your use of these features may result in the collection of biometric information. Biometric information is any information based on an individual’s biometric identifier used to identify an individual. Biometric information that may be collected depending on how you use Arlene’s products includes scans of an individual’s hand or face geometry. For example, if you are using Arlene VTO to scan a person’s hand or face geometry, that may be considered to be collecting biometric information under Applicable Laws. At this time, Arlene does not use these scans, but we do store the image in accordance with how you choose to store the data.

We use commercially reasonable organizational, technical, and administrative methods designed to protect biometric information within our organization.

We retain biometric information for as long as needed or permitted in light of the purposes stated in this policy, unless a longer retention period is permitted or required by applicable law. For more information on the criteria used to determine our retention periods, please see the “Retention” section above.

We will destroy or dispose of your biometric information as required by applicable law. For example, we may destroy electronic records of biometric information through such processes as overwriting magnetic media, degaussing, or physical destruction, and we may dispose of paper records by such processes as shredding or incineration.

Last Updated: September 1, 2021