DIGITAL CAPITAL PRIVACY STATEMENT

(Last updated 20 May, 2014)

Digital Capital AG develops and publishes products, online sites, social games and services for the web and mobile devices. Digital Capital AG (“Digital Capital”) respects the privacy rights of its online visitors and users of its products and services. Digital Capital recognizes the importance of protecting information collected from users and, in an effort to reflect our commitment to you, has adopted this privacy policy (“Privacy Policy”) to inform users about how Digital Capital gathers, stores, and uses information derived from their use of Digital Capital’s products, services, games, applications, and online sites (“Services”). If you access Digital Capital from a third party Social Networking Site (“SNS”), you may be required to also read and accept the Digital Capital Mobile Terms and Services and Privacy Policy.

This policy is current as of its last revision date. However, please note that this policy may be amended from time to time to reflect changes and additions to the privacy policy. Please check back for the most current version before relying on any of the provisions in this privacy policy.

Collection of Information

When you use any Digital Capital game at an SNS such as Facebook or Google +, where our games may also be referred to as “applications,” or by any other use of Digital Capital's online sites, products, games, and services, users agree that Digital Capital may collect personally identifiable information (as defined below). For users of mobile devices to access Digital Capital game, sites or other services, please read our Mobile Privacy Policy, which is incorporated herein by reference. Our Mobile Privacy Policy can be found here: http://digitalcapital.ch/mobileprivacy. Digital Capital will not share personally identifiable information with other parties except as described in this policy. Digital Capital may also collect aggregate information and individual information. "Aggregate information" is information that describes the habits, usage patterns, and demographics of users as a group but does not describe or reveal the identity of any particular user. "Individual information" is information about a user or user’s machine that is presented in a form distinguishable from information relating to other users but not in a form that personally identifies any user or enables the recipient to communicate directly with any user. Digital Capital may take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, no restrictions apply under this policy on our right to aggregate or de-personalize your personal information, and we may use and share in any way with third parties the resulting non-personally identifiable information. Digital Capital may share aggregate and individual information with other parties without restriction. Please note that this policy applies only to information submitted and collected online, and does not apply to information that may be collected by Digital Capital through any other means. The terms of this policy are subject to all applicable laws.

Personally Identifiable Information

"Personally identifiable information" is information that can be used to uniquely identify a user, such as name, address or credit card number. You may be asked to provide personally identifiable information in connection with the use of Digital Capital’ products, services and online sites. While Digital Capital collects personally identifiable information on a voluntary basis, for certain products and services, Digital Capital's collection of personally identifiable information may be a requirement for access to the product or service or to process a user’s order. If you prefer not to disclose such information, you will not be able to enjoy certain features of our Services.

Use of Personally Identifiable Information

Personally identifiable information is used internally by Digital Capital to develop, deliver and improve our products, content and services. In addition, Digital Capital may allow third parties performing services under contract with Digital Capital, such as order or payment processors or merchandise warehouse and fulfillment services, to access and use personally identifiable information, but only to the extent necessary to provide those services.

Digital Capital will not share personally identifying information with third parties for marketing purposes. Digital Capital may use personally identifying information provided by users to send information about Digital Capital, including news about product updates, contests, events, and other promotional materials, polls, surveys, and questionnaires, receive customer or technical support, or perform internal operations for our sites, offer feedback or other business inquiries, but only if the users agree to receive such communications. Digital Capital has no obligation to keep private personally identifiable information that a user makes available to other users via Digital Capital or other Digital Capital software, such as in multiplayer chat or other public functions.

External websites and companies with links to and from Digital Capital's online sites and products may collect personally identifiable information about users. Third party publishers may also collect personally identifiable information as a requirement of accessing their games or content. Digital Capital's privacy policy does not extend to these external websites and companies or third party publishers. Please refer directly to these companies and websites regarding their privacy policies.

Digital Capital may release personally identifiable information when we believe in good faith that such disclosures (a) are required by law, including, but not limited to, compliance with a court order or subpoena, or (b) will help to: enforce the Terms of Use; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security, including the safety and security that belongs to you; and/or, protect the safety and security of our websites or third parties. In the event of a reorganization, sale or merger we may transfer personally identifiable information to the relevant third party. In said event, we will include provisions in the selling contract requiring the purchaser to treat your personally identifiable information in the same manner required by this Privacy Policy, including any amendments thereto. The provisions of this paragraph will also apply if we are sold as part of bankruptcy proceedings. If we purchase a business, the personally identifiable information received with that business will be treated in the same manner as set forth in this Privacy Policy.

Children Under The Age of 13

Digital Capital will not knowingly collect personally identifiable information from any person age 12 and under. Digital Capital encourages parents to instruct their children to never give out personal information when online. Parents who are concerned about the transfer of personal information from their children may contact us.

Cookies and Other Information on a User's Machine

Digital Capital collects information through technology to make our Services more interesting and useful to you. For example, when you come to one of our Services, we collect your IP address. An IP address is often associated with the portal through which you enter the internet, like your ISP (Internet Service Provider), your company, or your university. Standing alone, your IP address is not personally identifiable. At times, we also use IP addresses to collect information regarding the frequency with which our guests visit various parts of our Services. We may combine this information with personally identifiable information.

Digital Capital’s products, services and sites may employ cookies and other technologies such as web beacons and pixel tags. Cookies are bits of electronic information that can be transferred to a user's hard drive to customize a person's use of a product or online site, keep records of a user's access to an online site or product, or store information needed by the user on a regular basis. Use of cookies is typically associated with websites. For example, when you sign in to Digital Capital, Digital Capital stores your user id and a combination of your IP address and time of login as a cookie on your hard drive. This cookie allows you to move from page to page without having to sign in again on each page. Similarly, if you enter information during your session, such as age verification data, this will be stored as a cookie and you will not have to re-enter such information during that session. We may also use third party web site analytic tools that employ cookies to collect certain non-personally identifiable information concerning use of our Services, such as referring web site addresses, page views and browser types.

Chat Forums, Etc.

Digital Capital's products or services may provide chat, forums, bulletin boards, or instant messaging tools to users. Any information that is disclosed in chat, forums or bulletin boards should be considered public information, and users who message one another may not know each other personally. Digital Capital has no obligation to keep private personally identifiable information that a user makes available to other users or the public using these functions. Users should exercise caution when deciding to disclose personal information in public forums. Users should also be aware that game play information disclosed during multiplayer game play (e.g. player name and current player statistics) is public information and may be displayed to other users.

Storage and Security of Personally Identifiable Information

The security and confidentiality of your personally identifiable information is extremely important to us. We have implemented technical, administrative, and physical security measures to protect your personally identifiable information from unauthorized access and improper use. Those measures include: maintaining information collected online behind a firewall-protected server; encrypting username and password information; limiting access to personal information to only those employees performing a legitimate business function; storing users’ personal information on off-site servers separate from other corporate information and systems; notifying by email or posting a notice on our website if Digital Capital learns that a data breach has occurred. From time to time, we review our security procedures to consider appropriate new technology and methods. However, please understand that, despite our best efforts, no security measure is perfect or impenetrable.

As part of our international operations, Digital Capital may transfer data to our subsidiaries, parent companies, joint ventures and other corporate entities under common ownership (“Affiliates”). Digital Capital stores information about site visitors and players on servers located in the Republic of Ireland (“Ireland”), and Digital Capital may also store such information on servers and equipment in other countries. Personal date collected with the European Economic Area (“EEA”) may be transferred to, and stored at a destination outside Ireland and the EEA. The data we hold may be processed by our agents operating outside Ireland and the EEA who work for Digital Capital or one of our Affiliates or for one of our agents or vendors. Such staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. By submitting your personal data or playing Digital Capital games, you agree to this transfer, storing and processing.

Digital Capital complies with the U.S.-EU Safe Harbor Framework regarding the collection, use, and retention of personal information from European Union member countries and the United States. Digital Capital has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. We will take reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy.

Our Services may contain advertisements from companies other than Digital Capital that may link to their own websites. We are not responsible for the privacy practices or the content of such websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly.

Choice/Opt-out

Digital Capital gives users the option to receive services like newsletter subscription, update on special events, game news, email announcements of interest to our users, and promotional email communications from Digital Capital. Users may opt out of these communications. Instructions for discontinuing receipt of promotional email communications from Digital Capital will be provided in email communications to users.

You may email us by filling out a customer support ticket at our support centre here:
http://digitalcapital.ch/contact

You may write us at the following address:
Digital Capital AG
Hofstrasse 1A
CH-6300 Zug
Switzerland
ATTN: Customer Support – Unsubscribe

Corrections, Updates and Removal of Personally Identifiable Information

If you are concerned about the accuracy of personally identifiable information maintained by Digital Capital or wish to review, access, amend or correct it, or would like your personally identifiable information removed from Digital Capital's records or otherwise deactivated, please contact us by filling out a customer support ticket at our support centre here:

http://digitalcapital.ch/contact.

We may decline requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, or are extremely impractical.

Contacting Digital Capital

If you have any questions or complaints about this Privacy Policy, or the privacy practices of Digital Capital, please contact us by filling out a customer support ticket at our support centre here: http://digitalcapital.ch/contact. You may also contact Digital Capital AG at the addresses below: Digital Capital AG

Hofstrasse 1
A
CH-6300 Zug

Switzerland


Privacy Policy Changes

We may amend this Privacy Policy at any time. If we make any material changes in the way we collect, use, or share your personal information, we will notify you by sending you an email at the last email address that you provided us, or by prominently posting notice of the changes on the respective Services covered by this Privacy Policy. Any material changes to this Privacy Policy will be effective 30 days following our dispatch of an email notice to you or 30 days following our posting of notice of the changes on the Services covered by this Privacy Policy. Please note that, at all times, you are responsible for updating your personal information to provide us your current email address. If the last email address that you have provided us is not valid, or for any other reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. You should periodically check www.digitalcapital.ch and this privacy page for updates.

In addition to the foregoing, the following links provide additional terms, conditions, policies, and guidelines to which you agree to abide by your continued usage of our Services:

Our Website Terms of Service: http://digitalcapital.ch/terms


Our Mobile Privacy Policy: http://digitalcapital.ch/mobileprivacy