NIVAL, INC.
PRIVACY POLICY

Effective Date: October 21, 2013

This Privacy Policy applies to your use of NIVALтАЩs online games and related services (the "Services") which are operated by Nival, Inc. ("NIVAL"). NIVAL operates its Services on the Internet and through social game platforms. In order for you to be able to utilize our Services and play our games, and for us to process your orders and requests, you do need to give us some personal information. However, we want you to know what information we need, why we need it, and how we make sure that your information is protected.

By accessing any of NIVALтАЩs Services, you agree to the terms of this Privacy Policy (and any updates thereto). By so agreeing, you authorize us to collect and use your information as outlined below. In the event you do not agree with this Privacy Policy (and any amendments which may be adopted by us), your only recourse is to cease use of our Services.

Please be aware that given that some of our Services exist on social network platforms such as Facebook, your activities on these social networks are beyond the scope of our Services themselves and are governed by that social networkтАЩs own privacy policy. We consider it a best practice for you to review the privacy policy of each website you frequent (as well as the privacy policies of any partners we may work with) in order to be an informed consumer and to fully understand how your personal information is being handled.

PERSONAL INFORMATION DEFINED

"Personal Information" is information that identifies you or that can be used to contact you (online or offline). Personal Information can include your name, email address, physical address, telephone number, gender, birthdate, etc.

COLLECTION OF PERSONAL INFORMATION AND PURPOSES

We collect Personal Information in a variety of ways in order to provide you with the best possible experience using our Services. Sources of information include:

Information You Provide To Us: You may choose to voluntarily provide us with information by registering or communicating with NIVAL. If you communicate with us, we will collect and record the information you have shared with us so that we can provide you with the Services or address your inquiry. During the registration process, we do collect basic information about you including your name and email address.

Social Networks: When you participate in our Services which are provided through a social network such as Facebook, we may obtain information about you from that social network such as your name, gender, geographic area and affiliations. Your gender designation on the social network may dictate the characters which are initially available to you while playing one or more of the games offered by NIVAL through its Services, though your gender does not limit you on the levels that you can achieve while playing the game (which in the free-to-play context reflects skill, not gender) and/or to a specific gameplay style. As a developer of an application which is provided through a social network, NIVAL is required to follow the developer policies of that social network. For example, FacebookтАЩs Platform Policies contain specific rules and restrictions which NIVAL is required to follow regarding the operation of its application on Facebook and the handling of personal information.

IP Addresses: We do monitor and store information about the IP addresses from which you access our Services. In general, these log files are used to monitor traffic on our Services, to troubleshoot technical problems and to collect aggregate information (e.g., to monitor and analyze demographic and preference information among our users). We may block certain IP addresses to comply with specific license agreements and/or in the event we detect user abuse of our Services. IP addresses could also be used to personally identify you in order to enforce our Terms of Service.

Cookies: We do utilize тАЬcookiesтАЭ on our site to facilitate user sign-on, and to retain user preferences and other information. A тАЬcookieтАЭ is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Although your browser may be pre-set to accept cookies, you can disable cookies or set your browser to alert you when cookies are being sent. Please note, however, that some parts of our Services will not function properly if you disable cookies.

Other Data Collection Mechanisms: We may employ technologies including (i) clear Graphics Interchange Formats (тАЬGIFsтАЭ) (i.e., web bugs, beacons or tags), which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation or registration; and (iii) local shared objects also known as flash cookies, which help us to prevent fraud, remember your progress on certain in-game tasks and in-game settings. Clear GIFs are not used to collect personal information about you. However, we may use clear GIFs to capture statistical usage information for our web pages, features or other elements on a web page.

AGGREGATED DATA; NON-PERSONAL INFORMATION DATA GATHERING AND ANALYTICS

In addition to Personal Information, we collect a variety of data that is not used to specifically identify or contact you. This type of data is used to analyze and enhance our Services.

Examples of such information include:

General Use Information: We may collect general information about our usersтАЩ interaction with our product such as your internet protocol address, browser type, referring and exit URLs, clicks, domain names, pages viewed, the amount of time spent viewing a particular page, the time such activities took place, etc.

Game Play Information: We may collect and retain information relating to your interaction with our Services. For example, we may monitor the number and type of activities you participate in during a particular session, your scores and the length of time you spend on our Services.

Analytic Metrics Tool and Other Technologies: Nival uses its own tools and technologies to analyze non-personal information when you use our Services The information collected may include data about your hardware system, mobile device (if applicable), media, Internet and website usage and how you use our Services. We also analyze and track your game statistics, feature usage and purchase history, as well as IP, MAC, Android and/or iOS Addresses, and mobile ID (as applicable).

Third Parties: We may use service providers to provide you with a superior experience and they may share information they collect about you with us. Personal Information you provide to those third parties will fall under their respective privacy policies. If such a third party provides us with your Personal Information, we will handle it in accordance with this privacy policy.

USER GENERATED CONTENT

User generated content includes various types of content which is publicly available and is produced by end users. For example, wall posts, messages, and actions with other end users would fall under this definition. It is possible that the user generated content you choose to provide may contain Personal Information. Please be aware that we cannot guarantee protection for information you make available publicly through comments, information sharing mechanisms, wall posts, etc. Any user generated content you share while using our Services on a social network, will very likely be disseminated broadly through the social network. Also, any Personal Information that is publicly shared by the user could be harvested by third parties (including by other users of the social network) with access to it and we cannot control those third parties' use of such information. Please bear these factors in mind before sharing any content with us.

WHAT WE DO NOT DO WITH YOUR INFORMATION

Social Network Data: We do not directly or indirectly transfer any personal information we receive from social networks such as Facebook to third parties. However, you should recognize that we may display the information we receive from social networks within our Services. For example, we may display your profile picture and name so people can identify you in the Services

We Do Not Sell, Lease, Rent Or Transfer Your Personal Information. We collect information for the purpose of improving our services. We may make certain aggregate information available to third parties (as outlined below), but we will not sell, rent, lease or otherwise transfer your Personal Information to any third parties except as provided in this Privacy Policy.

We May Log, But We Will Not Disclose, Individual Internet Protocol Addresses: We may maintain log files which contain IP addresses for purposes such as traffic monitoring. As you know, an IP address is a numeric address assigned to your computer (or router) by your Internet Service Provider. We will not disclose individual IP addresses to third parties.

WHAT WE MAY DO WITH INFORMATION WE COLLECT

Here are some of the things we may do with the Personal Information and non-personal information that we collect. If we determine there are additional things we would like to do, we will amend this Privacy Policy and notify you.

Enhancement of Services. We may use the information we collect to improve the quality of our games, facilitate gameplay as well as offer new features to you. This might include looking at how segments of our user population interact with our Services and what areas elicit the most interest. Further, we will also use the information we gather to optimize our content, provide you with more of what you like as well as to fix any bugs that we detect in our Services.

Notices. Occasionally, we do reach out to our players using the contact information you have given us in order to provide information concerning our Services or to announce a new game. You may opt out of these communications at any time.

Legal Requirements and Safety Issues. Please be aware, we will disclose information, including Personal Information, to the extent it may be necessary to prevent harm to third parties or if it is required by law. We may disclose information pursuant to subpoenas, court orders, or other requests if we have a good faith belief that the response is required by law. We may also share information when we have a good faith belief it is necessary to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating the Terms of Service. This may include sharing information with other companies, lawyers, courts or other government entities.

TRANSFER IN THE EVENT OF SALE OR CHANGE OF CONTROL

If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the services we provide you can continue to operate. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Policy.

In the event that we no longer operate a specific game through our Services, we may work with the subsequent game operator to offer you the ability to continue to play the game with the new game operator. This might involve inviting you to create a new user name and password in order to continue playing the game with the new game operator.

If material changes to Nival's privacy practices will occur as a result of a business transition, we will notify you and other users of the business transition prior to transferring your personal information as set forth below under Changes to Privacy Policy.

SECURITY OF OUR SERVICES

We use encryption and authentication tools to protect the security of the information that you share with us. Once we receive your transmission, we will do our best to protect its security on our systems. For example, all personal information we gather in connection with our Services is maintained on a secured server behind a firewall.

Unfortunately, while we strive to protect your personal information, no data transmission over the Internet can be guaranteed to be 100% secure and we caution you that any information you transmit to or from our Services is at your own risk. Accordingly, we disclaim liability for any theft, loss, or interception of or any unauthorized access or damage to any data or communications. By using the Services, you acknowledge that you understand and agree to assume these risks.

OPTING OUT

You may review, update, correct or delete personal information we receive from Facebook or any other social network by updating that information on your profile. If you elect to register with us and you would like to review, update, correct or delete that personal information, you may do so by removing and unsubscribing yourself in our email notifications.

LINKS

If you access our Services through a social network such as Facebook, links may appear in the same window or on screens before you commence playing. Any links you see adjacent to our Services may link you to parties completely unrelated to NIVAL. Because we cannot control the activities of third parties, we cannot accept responsibility for your use of their services or for any use of your personal information by such third parties and we cannot guarantee that they will adhere to the same privacy and security practices as ourselves. The presence of a third party link within the Services does not represent an endorsement of the content of that third party's link and NIVAL disclaims all liability arising from such content.

INTERNATIONAL

While the Nival Group operates games in multiple jurisdictions, Nival, Inc.тАЩs Services are hosted in the United States and are intended for and directed to Users in the United States. If you are a User accessing the Nival Services from the European Union, the Russian Federation, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from the laws of the United States, please be advised that through your continued use of the NIVAL Services (i) you are transferring your personal information to the United States and (ii) you consent to that transfer.

CALIFORNIA RESIDENTS

As set forth above in this Privacy Policy, we do not disclose personal information collected online to a third party for direct marketing purposes without your approval. However, under California law, we are required to notify California residents who have an established business relationship with Nival or one of its affiliated companies that they may choose to opt out of NivalтАЩs disclosure of personal information about them to third parties for direct marketing purposes. If you choose to opt-out at any time after granting approval, email privacy@nival.com or write to Privacy Policy Administrator, 2601 Ocean Park Blvd., Suite 205, Santa Monica, CA 90405.

OTHER JURISDICTIONS; RIGHT TO ACCESS PERSONAL INFORMATION

If you are resident in a jurisdiction which grants you the right to access the personal information that we maintain concerning you, your right of access can be exercised in accordance with applicable law. Please submit any requests for access to your personal data in writing to privacy@nival.com.

CHILDREN AND PRIVACY

Our Services are not directed to children under 13 years old. By using our Services, you represent and warrant that you are at least 13 years old. If we become aware that a user under the age of 13 has registered without prior verifiable parental consent, we will remove that user's personal information.

If you are using our Services through a social network, please be advised that under most social networksтАЩ terms of service and privacy policies (e.g., FacebookтАЩs Terms of Service and FacebookтАЩs Privacy Policy), children under age 13 are prohibited from accessing and using such social networks.

If you believe that we might have collected any information from a child under age 13, please contact us at privacy@nival.com so that we can investigate and remove the information.

CHANGES TO PRIVACY POLICY

In the event Nival makes any changes to its Privacy Policy, it will post the updated policy on its Services. You may also be given additional notice, such as an e-mail message or through a notice which appears within one of our games or on our Services. You will be deemed to have accepted such changes by continuing to access the Services. Except as otherwise stated, all amended terms shall automatically be effective 30 days after they are initially posted. NIVAL may also revise other policies, codes or rules at any time, and the new versions will be available on www.nival.com or from within the applicable game.

INQUIRIES

If you have any questions or concerns, please email us at privacy@nival.com