PRIVACY STATEMENT

INTRODUCTION

WSC Solitaire, LLC has developed and published social games for the web and mobile (the “Service”). In this policy, “WSC Solitaire, LLC” refers to Churchill Solitaire, WSC Solitaire, LLC and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We may also refer to WSC Solitaire, LLC as “We” or “Us”.

This Privacy Policy describes:

 The information We collect, how we do so and the purposes of our collection

 How We use and with whom We share such information

 How you can access and update such information

 The choices you can make about how We collect, use and share your information

 How We protect the information We store about you

If you have questions regarding this Privacy Policy or our collection and use of information, please contact us as described in the Section “Contact Us”.

INFORMATION WE COLLECT

When you use any WSC Solitaire, LLC game, also referred to as an “application” or “app”, you get access to its online community within that game and you allow WSC Solitaire, LLC to access certain information from your profile for that application. The information you allow WSC Solitaire, LLC to access varies by application, and it is affected by the privacy settings you and your friends establish in that application. You can control and find out more about these settings within the application. For example, WSC Solitaire, LLC may access and store some or all of the following information, as allowed by you and your preferences:

 Your in-game username

 Your device’s MAC address

 Facebook User ID

 Facebook Fan Status

 Your physical location and that of your access devices

By playing a WSC Solitaire, LLC game, you are authorizing WSC Solitaire, LLC to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the application could provide to WSC Solitaire, LLC through the EULA – End User License Agreement – posted on the application portal you downloaded the app from. Your agreement takes place when you “accept” or “allow” (or similar terms) one of our applications.

INFORMATION WE COLLECT FROM YOU DIRECTLY

When you interact with the application, at http://www.churchillsolitaire.com, or any WSC Solitaire, LLC-owned website, We may collect and store information from you directly as described below:

REGISTRATION INFORMATION

We may allow you to “register” with Us by using Facebook Connect or other Application authentication options to create an account or profile within the Service. We may also provide a more typical registration flow where you may be required to provide the following information: your age or birthday (for age screening and/or to better understand who our users are); your e-mail address; a password and other information that helps Us confirm that it is you accessing your account.

We may also offer you the option to complete a user profile that is visible to other WSC Solitaire, LLC users. Your user profile may include: a profile image; one or more game username(s); and a WSC Solitaire, LLC user ID number that is created by WSC Solitaire, LLC and used to identify your profile.

INFORMATION WE RECEIVE OR COLLECT WHEN YOU ACCESS WSC SOLITAIRE, LLC GAMES ON A MOBILE DEVICE

If you play WSC Solitaire, LLC games on your mobile telephone or other mobile device, including iPads and tablets, we collect mobile device identifiers, including MAC Address, and possibly IP Address. In certain games we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, geo-location or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Service.

PAYMENT INFORMATION

WSC Solitaire, LLC may also receive the billing and payment information that you provide when your purchase is processed by another party, such as Facebook (for Facebook Credits), Apple (for purchases on iOS devices), Google (for purchases on Android devices), or Amazon (for purchases on Kindle devices).

CUSTOMER SUPPORT CORRESPONDENCE

When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game play or activity on the Service, and your username or ID number. We will also store the correspondence and any information contained within.

PUSH NOTIFICATIONS & LOCAL NOTIFICATIONS

With your consent we may send push notifications to your mobile device to provide game updates and other relevant messages. You can manage push notifications from the Social section within the relevant game.

TECHNICAL AND USAGE INFORMATION

When you access our websites or play our games, We collect (i) certain technical information about your mobile device or computer system, including MAC Address, IP Address and mobile device ID; and (ii) usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files (“Log Files”), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number(s). For more information on how We utilize cookies and other tracking technologies please review the “Cookies and Automated Information Collection” discussion under (“How We Collect Information about You”).

HOW WE COLLECT INFORMATION ABOUT YOU

We may collect information about you in any one or more of the following ways:

INFORMATION ABOUT PLAYERS AND PLAY

To provide a richer game play and social experience, We collect information about your play and interaction with other players. The bulk of this information is collected and stored through the use of Log Files, which are files on our web servers that record actions taken on our games and websites.

COMMUNICATIONS FEATURES

You may be able to take part in certain activities on our websites or games that give you the opportunity to communicate or share information not just with WSC Solitaire, LLC, but also with other users of our Service. These include:

 Participating in player forums and message boards

 Posting public comments to other users’ profiles or gameboards

 Sending private messages or invitations to other users, either directly on our websites or to their e-mail accounts

 Chat with other users

 Posting web links

We may record and store archives of these communications on WSC Solitaire, LLC’s servers to protect the safety and well being of our users and WSC Solitaire, LLC’s rights and property in connection with the service. You acknowledge and consent to the recording and storage of such communications for these purposes.

COOKIES AND AUTOMATED INFORMATION COLLECTION

When you access the Service, We collect certain technical information in order to (i) analyze the usage of our sites and services; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf, such as Google Analytics, use Log Files and tracking technologies to collect and analyze certain types of technical information, including cookies, IP addresses, device type, device identifiers, browser types, browser language, referring and exit pages, and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, game state and the date and time of activity on our websites or games, and other similar information. In some cases, We will associate this information with your user ID number for our internal use.

OTHER SOURCES

We may collect or receive information from other sources including (i) other WSC Solitaire, LLC users who choose to upload their email contacts; and (ii) third party information providers. This information will be used to supplement your profile – primarily to help you and your friends connect. It will be combined with other information We collect.

HOW WE USE THE INFORMATION WE COLLECT

In general, We collect, store and use your information to provide you with a safe, smooth, efficient, fun, and customized experience. For example, We may use information collected from you in any one or more of the following ways:

 To create your game accounts and allow play of our games

 To identify and suggest connections with other WSC Solitaire, LLC users

 To enable user-to-user communications

 To provide technical support and respond to user inquiries

 To prevent fraud or potentially illegal activities, and enforce our Terms of Service

 To deliver and target advertising

 To notify users of in-game updates

 To provide in-game leader boards and promote in-game player achievements

 To solicit input and feedback to improve WSC Solitaire, LLC products and services and customize your user experience

 To inform users about new products or promotional offers

 To engage in commonly accepted practices, such as contacting you at the email address We have on file if you are a potential winner in a sweepstakes

One important use of your information is communication. If you have provided your e-mail address to WSC Solitaire, LLC, We’ll use it to respond to (i) customer support inquiries, and (ii) keep you informed of your in-game activity, including comments from friends, notifications about in-game status and requests. Some messages, such as invites for friends to join you in a game, may include your name and profile photo. We may also send promotional e-mail messages and promotional messages (“Promotional Communications”) directly or in partnership with parties other than WSC Solitaire, LLC. Each Promotional Communication will generally offer recipients choices about receiving additional messages.

SHARING OF YOUR INFORMATION

We will share your information (in some cases personal information) with third parties, that is parties other than WSC Solitaire, LLC, in the following circumstances:

THIRD PARTY SERVICE PROVIDERS

We will provide your information to third party companies to perform services on our behalf, including payment processing, data analysis, e-mail delivery, hosting services, customer service and to assist Us in our marketing efforts. We direct all such third party service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on WSC Solitaire, LLC’s behalf.

ADVERTISING OF THIRD PARTY PRODUCTS AND SERVICES

We do not actively share personal information with third party advertisers for their direct marketing purposes unless you give Us your consent. We may share (i) aggregated information (information about you and other users collectively, but not specifically identifiable to you); (ii) anonymous information; and (iii) certain technical information (including IP Addresses, MAC Addresses for mobile devices and mobile device IDs) to develop and deliver targeted advertising in the Service and on the websites of third parties. We may also allow advertisers to collect these types of information within the Service and they may share it with Us. Advertisers may collect this information through the use of tracking technologies like browser cookies and web beacons. The information collected may be used to offer you targeted ad-selection and delivery in order to personalize your user experience by ensuring that advertisements for products and services you see will appeal to you, a practice known as behavioral advertising, and to undertake web analytics (i.e. to analyze traffic and other end user activity to improve your experience). To learn more about behavioral advertising or to opt-out of this type of advertising for participating ad networks, you can visit the Network Advertising Initiative or the Digital Advertising Alliance.

Our collection, use, and disclosure of anonymous or aggregated information are not subject to any of the restrictions in this Privacy Policy.

OFFER WALLS

WSC Solitaire, LLC games or their purchase pages may display an “offer wall” that is hosted by an offer wall provider. The offer wall allows third party advertisers to provide virtual currency to users in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These are not offers made by WSC Solitaire, LLC. These offers may be displayed to you based on certain technical information, such as your geographic area or anonymous demographic information. After clicking on one of these advertisements, you will no longer be on a site hosted by WSC Solitaire, LLC or a partnering social network. To properly credit user accounts and to prevent fraud, a unique identifier, in some cases your user ID number, will be shared with the offer wall provider.

SAFETY, SECURITY AND COMPLIANCE WITH LAW

Your information, and the contents of all of your online communications (including without limitation chat text, voice communications, IP addresses and your personal information) may be accessed and monitored as necessary to provide the Service and may be disclosed: (i) when We have a good faith belief that We are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any applicable laws or regulations; (iii) where We believe that the Service is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) when We have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) in order to protect the rights or property of WSC Solitaire, LLC.

SALE OR MERGER

In the event that WSC Solitaire, LLC undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, We may transfer all of your information, including personal information, to the successor organization in such transition. If material changes to WSC Solitaire, LLC’s privacy practices will occur as a result of the business transition, We will notify you and other users (in the manner described in Changes to Our Privacy Policy below) of the business transition prior to transferring your personal information.

OPTING OUT OF PUSH COMMUNICATIONS

When you install our apps on your mobile device you can choose to receive push notifications. You can turn off push notifications by visiting the “options” or “settings” page within the relevant game. You may also receive local notifications. You can turn off local notifications by visiting the “options” or “settings” page within the relevant game.

PRIVACY POLICIES OF LINKED SITES AND ADVERTISERS

Our websites and games may contain advertisements from companies other than WSC Solitaire, LLC 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.

SECURITY OF YOUR INFORMATION

WSC Solitaire, LLC implements reasonable security measures to protect the security of your information both online and offline, and We are committed to the protection of customer information.

While We take reasonable precautions against possible security breaches of our websites and our customer databases and records, no website or Internet transmission is completely secure, and We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If your account is hacked, this may lead to unauthorized play of your WSC Solitaire, LLC games, so be careful to keep your account information secure. If you have questions about the security of our websites, please contact us at support@churchillsolitaire.com

Unfortunately, the transmission of information over the Internet is not completely secure. Although We strive to protect your personal data, We cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once We have received your information, We have procedures and security features in place to try to prevent unauthorized access.

CHANGES TO OUR PRIVACY POLICY

If We decide to make material changes to our Privacy Policy, We will notify you and other users by placing a notice on WSC Solitaire, LLC.com or by sending you a notice to the e-mail address We have on file for you. We may supplement this process by placing notices in our games and on other WSC Solitaire, LLC websites. You should periodically check http://www.churchillsolitaire.com and this privacy page for updates.

YOUR PRIVACY RIGHTS

We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by “opting in” to receive information from a third party that is participating in a sweepstakes or other promotion on one of our sites. If you do ask Us to share your personal information with a third party for its marketing purposes, We will only share information in connection with that specific promotion, as We do not share information with any third party (other than our service providers) on a continual basis. To prevent disclosure of your personal information for use in direct

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