Privacy Policy is owned and operated by FlowPlay, Inc. ("FlowPlay”, "we," "us").  We are committed to providing a fun, entertaining, and safe experience for users of This Privacy Policy outlines how we handle Personal Information (defined below) we collect from you when you visit or use any products and services available from the other sites we operate (“Websites”).  It also applies to any Personal Information we collect by other means for example, if you email us or provide us information over the phone.


This policy (“Privacy Policy”) describes, among other things:

This Privacy Policy also outlines how we handle Personal Information we collect from individuals in in the European Union and Switzerland, including the purpose and legal basis for collecting that information, how long we retain it, and your right to object to the collection of the information.  

Together with our Terms and Conditions of Websites Use ("Terms"), this Privacy Policy is a legally binding agreement between you and us. Please read this Privacy Policy carefully.  By using the Websites or registering for a user account, you indicate your agreement with, and intent to be bound by, this Privacy Policy and represent and warrant that you (a) are at least 18 years old; (b) have reached the age of legal majority in the country, state, province or locality ("Jurisdiction") in which you reside; and (c) are permitted under the applicable rules, regulations, statutes, agency or court decisions or other acts of government ("Laws") to access the Websites.  

We may, from time to time, unilaterally modify this Privacy Policy without notice to you, so it is important that you review this Privacy Policy and the Terms every time you use the Websites.  Please do not use the Websites or register for a user account if you do not agree to the Terms or this Privacy Policy.


This Privacy Policy applies only to Personal Information.  It does not apply to data we collect that cannot be used to identify an individual or to pseudonymous data. Nor does it include encoded or anonymized information or aggregated data which we collect or create about a group or category of services, features or users which does not contain personally identifying information.  We reserve the right to share aggregate, encoded, or anonymized information with potential partners or other third parties without restriction.

What is Personal Information?

For the purposes of this Privacy Policy, Personal Information is your first and last name, your e-mail address, your home or other physical address, including a street name and name of a city or town, your telephone number, your social security number, any payment or financial information, or any other identifier that permits us to contact a natural human person, like you, and/or any information that we maintain that could be used to identify you in combination with any of the identifying information described above.

Why do we collect Personal Information?

We collect and process Personal Information to improve our products and services, to deliver them to you, to perform obligations under contracts we have with you, to comply with our own legal obligations and for other purposes as described below.  This includes to send you information you have requested as well as information about our new games or features and other products and services that may be of interest to you.  If you do want to receive communications from us, you can use the opt-out process outlined below and, if you want to review, correct, or remove Personal Information we have collected, you can do so by following the steps under Access to Personal Information.  

What Personal Information Do We Collect?

We collect Personal Information you provide to us and from your use the Websites and/or our products or services, including when you play our games.  We also collect Personal Information from other sources and when you call us or send us email.

Information You Provide to Us:  We will collect and store any Personal Information you provide to us, except that we will not store payment card numbers and other financial transaction data, except as necessary to process your payment. For example, to create a user account for the Websites ("Account") we ask you to provide an email address and username. We may also ask you to provide other Personal Information in connection with other features on the Websites (such as the ability to upgrade your Account for a fee, the ability to buy certain Virtual Items on the Websites, demographic details in response to surveys about our games, information necessary to enter or collect a prize as part of a contest or sweepstakes we may offer) and if you choose to provide it, we will collect and store it in accordance with this Privacy Policy. Please note: it is your choice to provide us with this information.  If you decide not to provide the information, you will not be able to set up an Account or use some of the other features of the Websites.  But, you may choose to access and use the Websites as a guest (without providing us with your name and similar information), in which case we do not collect that information, although we may collect other information as described in this Privacy Policy.

Account Information: If you choose to create an Account, you will be asked to select a user name and a character to represent you on the Websites. The user name will be visible to all other users (including guest users) and to us. We will collect and store this user name; however, we strongly encourage you not to include any Personal Information in your user name. In addition, we may collect other information you provide to us through your Account, such as your favorite color, images captured using our in-game photo function, Virtual Items you have purchased, and other non-Personal Information and other information of this kind. This Account information will also be visible to other users (including guest users) unless you select otherwise in your Account's User Settings.

Information You Provide to Other Users: You may choose to disclose information about yourself in our on-line chat rooms or other multi-user communication functions available on the Websites. We strongly encourage you not to disclose Personal Information about yourself. We will collect and store all chats and similar interactions between and among users, including any information contained in those interactions.

Automated Collection:  We automatically receive and store certain types of Personal Information when you visit the Websites, such as the name of the domain and host from which you access the Internet; the IP address of the computer you are using and the browser and operating system you are using; the date and time you access the Websites; the Internet address of the website from which you linked to the Websites; any search terms you used to find the Websites; the device identifiers and mobile and network information, and your actions on the Websites. This information will be treated as Personal Information if we combine or link it to any of the identifying information above. Otherwise, this information constitutes aggregate information.

Game-Play:  When you play our games, we record your gameplay and statistics and add this information to your profile, which can be viewed by other players.

Credit Card Information:  In some cases we will require your credit card information in order process purchases.  This includes your name, credit card number, expiration date, billing address, and authentication codes or related information as needed to authorized the charge and complete the transaction.  Credit card data is transferred over a Secured Sockets Layer (SSL) line if you are using a SSL enabled browser such as Microsoft Internet Explorer, Firefox, Safari, or Google Chrome.  We also use SSL on other select pages where you enter Personal Information. This ensures that the Personal Information is encrypted as it travels over the Internet. This secure mode is enabled before any such information is transmitted from your computer. You will know you are in secure mode when the padlock or key icon in the lower right-hand or left-hand corner of the computer screen appears in the locked position. In addition, when accessing a secure server, the first characters of the site address will change from http to https. After information reaches us it is stored on a secure server that resides behind firewalls designed to block unauthorized access from outside FlowPlay.

Purchases:  If you purchase or pay for services via the Site, the transaction may be handled by our service vendor(s) responsible for processing your payment (and its affiliates or agents) (“Payment Processor”).  These entities have their own privacy policy and those terms will apply to you.  Please be sure to review them at the links provided during payment processing. The policies of the Payment Processor are also considered a part of this Privacy Policy and part of your agreement with us. If you use another website to purchase our services, you do so at your own risk and you should carefully review the privacy policy and terms of any such websites.

Log Data:   Our web servers may collect “log data.” Log data provides aggregate information about the number of visits to different pages on the Websites. We use log data for troubleshooting purposes and to track which pages people visit in order to improve the Websites. We do not link log data collected to Personal Information. Third-party vendors may also collect aggregate log data independently from us.

Cookies:   We automatically receive and store certain types of information when you visit the Websites through the use of cookies, web beacons, or similar programs to collect the information described above.  Cookies are strings of text that a website may store on your computer. Cookies enable the Websites to keep track of your preferences and activities when you use or visit the Websites.  The Websites create session cookies for each visit in order to facilitate your visit. The session cookie expires at the end of the session. We may also use “persistent” cookies, which remain on your device for much longer.  Cookies do not corrupt or damage your computer or computer files.  We use cookies for authentication, to remember your settings, to keep track of your activity during a visit to the Site, to conduct usability tests, to improve Site performance, and to implement certain features of the Site.  You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. If you do not wish to receive these cookies, you may set your browser to reject the cookies (consult the instructions for your particular browser on how to do this), although doing so may affect your ability to perform certain transactions on the Websites.

Web Beacons: Some of the pages on the Websites may contain electronic images known as web beacons that allow use to count the number of users who have visited those pages.  These collect only limited information such as a cookie number, time and date of a page view, and a description of the page on which the web beacon resides.  These web beacons do not carry any personal Information and you cannot opt-out or refuse them.  However, where they operate with cookies, you can render them ineffective by opting out of cookies or changing the cookie setting in your browser.

Marketing e-mails:  We use third party service providers to send our marketing e-mails.  There are no cookies in the e-mail. However, when an e-mail recipient clicks on a link to the Websites included in the e-mail, a persistent cookie is placed on the user's computer. This cookie is used to measure the effectiveness of our e-mail marketing efforts, better understand how our users navigate through the Websites, and enhance user experience.  To that end, we collect a variety of information about how users interact with our marking efforts, including how many times the email is opened and/or clicked, the browser type used, operating system, user email program, etc.   The cookie set by our service providers will remain on your hard drive 30 days after the last time you clicked on the coded link in the e-mail, or until you delete it.  

In addition, the third parties that assist with our marketing e-mails may use pixel tags that help us send the e-mail in a format you can read, to allow us to know which e-mails you act upon and to better target the content of future e-mails.  We also use these tags to track the aggregate number of e-mails read and whether any of the links in the e-mail were accessed.  

Advertisements:  We use third party service providers to serve and host our advertisements. These third parties use persistent cookies to track the number of times our site is accessed and whether the site was accessed from the advertisement. The cookies generated from the advertisements do not contain Personal Information and may remain on your hard drive three or more years unless you delete them.  If you do not want Personal Information about you used for this purpose, you may opt-out by following the procedure described below.  Note, however, that where we use a third party to provide advertising, email marketing or similar services, each such third party will have its own opt-out process, which it will manage and control.  You will need to follow those procedures to opt-out of the services they provide.

Invite a Friend: You may invite friends to join by using the "invite a friend" feature on the Websites. You will be required to submit your name and email address, as well as your friend's name and email address. Your friend's Personal Information that you submit in this feature will be used only to send the email you request, and will not be stored or maintained by

Social Media Integration: We may provide you the opportunity to connect your Account with other social media platforms, including Facebook. When you participate in social features the information you provide may be shared with others by the operators of those platforms.  We do not have any control over any third-party's use of Personal Information or any other information you may make available on those platforms, so please be sure to read the applicable Privacy Policies carefully to determine whether you want to connect.

Information From Third Parties:  If you play our games on a mobile device and/or tablet or from a console or through a service operated by a third party, we receive information about you from the platform provider.  This information includes your username and/or device ID and other information necessary to validate your Account, but does not include any sensitive or financial information.  These platforms may also send other information to us as you authorize.  In addition, we may request additional information from you such as your precise location or contact list, which we will only collect if you give your explicit consent.

Analytics Technology:  We use our own analytics technology to collect information about how you use our products, your computer or device and the health of our products.  This includes information about your gameplay and usage statistics.   We may collect, store, transmit and publicly display statistical data regarding game play.

In addition, we use third party analytics services to collect information about our products and how you use them.  These third parties may combine information they collect from your use of the Websites with other information they have collected from other sites or sources.  These parties collect and use information under their own privacy policies.  We do not control information that is sent to these parties from your browser or in the normal course of your internet activity or use of our Websites.  A representative list of third party analytics companies we use or whose products operate in games or the Websites include: Google Analytics, Kochava, Game Analytics and Google Firebase.

Fraud Prevention:  When you create an Account or log into your Account or make purchases through the Websites, we or third parties may use cookies and similar technologies, or collect data about the device you are using to create a device “fingerprint” or “hash” for fraud prevention, security and authentication purposes.  We may also use other technology to ensure that users of our games are playing them fairly.  This technology also collects information about you and the devices you are using to play the games which is then used to detect anomalies associated with violations of our Terms.  


We take protection of the privacy of legal minors very, very seriously and in order to adhere to the Children's Online Privacy Protection Act. We will not knowingly collect any Personal Information from individuals under 13 or knowingly allow individuals under 13 to create an Account. If we learn that we have collected Personal Information from an individual under 13 we will immediately remove such Personal Information from the Websites and our systems.

How We Use Personal Information

We may use the Personal Information to:

We generally store Personal Information in the United States as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, as indicated to you at the time of collection, as we determine is necessary for business records, and as required under applicable law. However, we may transfer your Personal Information from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our business. By providing any information to us, you consent to such transfer, storage, and processing.

Disclosure of Personal Information to Third Parties

General:  We do not share the Personal Information provided or obtained through the Websites with third parties, except as described below and as otherwise specified in this Policy. We may share Personal Information as follows:

Affiliates: We share much of our data, including Personal Information about you, with our affiliated entities and joint ventures when it is reasonably necessary for the purposes otherwise permitted in this Privacy Policy.  

Service Providers:  We use third party service providers to provide specific business support services to us which may involve limited access to Personal Information.  We require these companies to use the information only to provide the contracted services and prohibit them from transferring the information to another party except as needed to provide the contracted services. Examples of such services include sending emails, conducting and administering promotions, executing surveys, providing customer service, performing business analysis, and processing payments. When we employ another company to perform a function for us, we only provide them with the information that they need to perform their specific function. We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties.

Business Transactions:  We may disclose your Personal Information as part of any merger, sale of company assets or acquisition, as well as in the event of an insolvency, bankruptcy or receivership.  The recipient of Personal Information following such actions may have privacy policies that differ from those in this Policy.  You will be notified via email and/or a prominent notice on the website, and you may opt-out of the use of your existing information in a new manner.

Special Events:  If you choose to participate in a special event (for example, a promotion, contest, or sweepstakes), we may share Personal Information with those organizations participating in the applicable event.

For Commercial Use by Others:  We will never sell, transfer or otherwise disclose your Personal Information to any third-parties for their own commercial, marketing or promotional use. If we intend to collect and disclose Personal Information for such purposes, including if certain features on the Websites require such disclosure of your Personal Information, we will notify you first, such as on the Websites at the time we collect the Personal Information.

Other Purposes: We may use and share Personal Information for other purposes with your consent.

Disclosure: Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any Personal Information about you.  To request this information please contact us at

Other Privacy Policies:  Any third parties to whom we may disclose Personal Information may have their own privacy policies that describe how they use and disclose Personal Information. Those policies will govern use, handling, and disclosure of Personal Information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.

Aggregate Information:  We may disclose to third parties certain aggregate information contained in your Account or other aggregated, anonymous information (such as that collected automatically) as we deem appropriate for our internal business purposes, including improving the Websites and adding or modifying features.

Commercial Electronic Message Consent

By providing your email address to us, you affirmatively and expressly consent to receiving commercial emails from us and those parties that process email communications on our behalf.  These third parties may send you commercial emails in order to deliver the updates about our products, to provide you with more information about available products you have purchased, and to provide you with special offers, and other information.

Opting Out

We give you control over how much Personal Information you provide to us and how we are permitted to use it. The simplest way to exercise this control is to not provide us with Personal Information you do not want us to collect, store and use as set forth in this Privacy Policy. However, subject to our ability to retain certain Personal Information and our ability to disclose Personal Information, each as described above, you can also control certain aspects of how we use Personal Information we have collected about you:

Please be aware that we reserve the right to verify the identity of any person making an opt-out or correct/update request; provided that we shall have no liability whatsoever resulting from false or erroneous requests.  Note that we may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our products. Otherwise, we will retain Personal Information about you for as long as reasonably necessary to provide you services, create and improve our products, comply with the law, and to run our business.

Links and Third Party Ads

From time to time we may provide advertisements for third-party goods and services or links on the Websites to third-party websites as a service to you. These third-party goods, services, and sites, including any cookies placed on our Websites by such third-parties, are not covered by this Privacy Policy. Please remember that the third party sites, including their cookies, are operated by companies that are outside of our control, and your activities at those sites will be governed by the policies and practices of those third parties. We encourage you to review the privacy practices of these third parties before disclosing any Personal Information, as we are not responsible for the privacy practices of those sites.


We use reasonable technological and procedural measures to protect the Personal Information you provide and we urge you to help us protect you by selecting user names and passwords difficult to hack and by keeping your user name and password secret. We take protection of your Personal Information seriously; however, we cannot guarantee the safety or privacy of your Personal Information. You acknowledge, agree and understand that communication via the Internet, and security measures in connection with such communication, are not failsafe or foolproof, and there is always a possibility that data, including Personal Information, may be lost or intercepted by unauthorized parties during such transmission or after receipt. You agree that shall have no liability whatsoever in connection with such lost or intercepted data.

To learn more about how to protect yourself online, we encourage you to visit the website

Transfer of Personal Information Across Jurisdictional Boundaries

As indicated in our Terms, this Privacy Policy is governed and construed in accordance with applicable United States and State of Washington Laws. However, we may transfer Personal Information and store it outside of the United States or the Jurisdiction in which you are located, which may result in the provision of less protection than might be provided in your home Jurisdiction.

Disclaimers, Liability and Indemnity

Please be sure to review the Terms which contain important information about, among other things, our disclaimer of liability for damage arising out of your use of the Websites (including in connection with this Privacy Policy), your assumption of risk and indemnity obligations in connection with the User Agreement.

Changes to Privacy Policy

We may change the Websites, the User Agreement and this Privacy Policy at any time and in our sole discretion. We will post the updated version on the Websites and we will notify you by other means if we think the changes will significantly impact the treatment of Personal Information you have already provided. Your continued access to or use of the Websites shall constitute acceptance of any modifications of the Privacy Policy. Our use of information gathered or obtained at any time is subject to the Privacy Policy in effect at the time of such use. If you have any questions or concerns after reading this, please email us at:

Your California Privacy Rights

Effective January 1, 2005, under California Civil Code Section 1798.83, if an individual who is a California resident has provided Personal Information to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual's Personal Information to a third-party and knows or should have known that such third-party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what Personal Information was shared and with whom it was shared. Any request for a disclosure required under this California law should be sent to us via email at or via regular mail at the address set forth below. Please note that under this law, we are not required to respond to a customer's request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email or mailing address designated above.

Section 22575 of the California Business & Professions Code requires website and online service operators to disclose whether they honor web browser "Do Not Track" settings. We support and honor "Do Not Track" web browser settings. If you enable Do Not Track settings in the browser you are using, we will not collect, store, or use information about websites you visit using that browser other than Other parties, however, may not honor Do Not Track signals. These parties may collect Personal Information about your online activities over time and across different web sites when you visit, for example by using cookies on our site. We have no access to or control over other parties' information collection practices, even those with which we may have an affiliation. You should carefully review the privacy policy and terms of any website you visit. For more information about Do Not Track, please visit

International Visitors

The Websites and the services are hosted in and provided from the United States. If you use the Websites and/or the services from the European Union, Switzerland, Canada or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data to the United States. The United States does not have the same data protection laws as the EU, Canada and some other regions. By providing your Personal Information, you consent to the transfer of your personal data to the United States and the use of your Personal Information, in accordance with this Policy.

Contact; Complaints

We take your privacy seriously, and invite you to contact us at the address below with any questions or concerns you may have regarding this Privacy Policy or our collection, storage, and use of your Personal Information:

FlowPlay, Inc.

1008 Western Ave, Suite 300

Seattle, Washington 98104

Should you so choose, however, you have the right to lodge a formal complaint regarding our use of  Personal Information about you with the Federal Trade Commission, the supervisory authority for the United States, using the following contact information:

Federal Trade Commission

600 Pennsylvania Avenue, Northwest

Washington, DC 20580

Tel. +1 202 326 2222

Terms Applicable to Data from EU Member Countries

We are based in the United States.  In most cases, the Personal Information we collect is stored and used in the United States.  While we do not direct our services to individuals of the European Union (EU), it is possible that EU individuals may access and use the Websites.  

Compliance with General Data Protection Regulation (GDPR)

If we collect Personal Information from individuals in the EU  in a manner subject to the General Data Protection Regulation then, in addition to the above, the following terms shall also apply to our collection, use and retention of that information:

Basis for Collection:  As set out above, we collect and process Personal Information for which you have given your express consent at the time of collection.  For example, we collect Personal Information when you elect to participate in one of our promotions.  We also collect and process Personal Information to order improve our services, to deliver services and perform obligations under contracts we have with you, and to comply with our own legal obligations.

Your GDPR Rights:  Your rights include: (a) a right to withdraw your consent to the processing of Personal Information about you to which you have previously given consent; (b) a right to object to processing of Personal Information about you for the purpose of direct marketing; and (c) a right to have incorrect Personal Information about you corrected.  You also have the right to obtain a copy of the Personal Information we have about you, although we reserve the right to charge a fee for this.      

GDPR Questions and Complaints:  If you have questions or complaints regarding this Policy or our handing of Personal Information about you, please contact  We will promptly investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Privacy Policy.

You also have the right to lodge a privacy complaint with a European supervisory authority. The data protection authorities are listed here at

Profiling:  We may analyze Personal Information we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you.  We may make use of additional information about you when it is available from external sources to help us do this effectively.  We may also use Personal Information about you to detect and reduce fraud and credit risk.  

Compliance with Privacy Shield Principles: complies with the EU-US Privacy Shield Framework and and the Swiss-US Privacy Shield Framework  as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield has certified that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

Sensitive Data:  We do not collect Sensitive Data from visitors to the Websites.

Onward Transfer:  Except as otherwise provided in this Privacy Policy, we only disclose Personal Information to third parties who reasonably need to have access to it for the purpose of the transaction or activity for which it was originally collected or to provide services to or perform tasks or our behalf or under our instruction. All such third parties must agree to use such the Personal Information we provide to them only the purposes for which we have engaged them and they must agree in writing to provide adequate protections for the Personal Information that are no less protective than those set out in this Privacy Policy.  Where we have knowledge that an entity to whom we have provided Personal Information is using or disclosing Personal Information in a manner contrary to this Privacy Policy, we will take reasonable and appropriate steps to prevent, remediate or stop the use or disclosure. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield Frameworks, is potentially liable.

Authorized Transfer:  We also may disclose Personal Information for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we will disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are not liable for appropriate onward transfers of personal data to non-agent third parties.

Data Processors:  We may retain third parties to process or analyze personal Information we collect from the Websites.  For example, a Site may be maintained or hosted by a third party service provider, a promotion may be administered by a sales promotion agency, and/or products may be fulfilled by a wholesaler.  These suppliers and other third parties who provide services for us are contractually obligated not to use Personal Information about you except as we authorize.  

Your Privacy Shield Right of Access:  Your rights include: a right to access information we hold about you and to have incorrect Personal Information about you corrected.  

Privacy Shield Enforcement and Disputes:  In compliance with the Privacy Shield Principles, commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant o Privacy Shield . European Union and Switzerland individuals with Privacy Shield inquiries or complaints should first contact at: has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through these channels, you may complain to your home data protection authority and as a last resort, may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  Contact details for the EU data protection authorities can be found at  

The Federal Trade Commission has jurisdiction over our compliance with this Privacy Policy and the EU-US Privacy Shield Framework and and the Swiss-US Privacy Shield Framework.

Effective May 15, 2019.