1. INTRODUCTION

Free Best Spider Solitaire develops and publishes social games for the web and mobile devices. In this privacy policy, “Free Best Spider Solitaire,” “we,” or “us,” refers to Free Best Spider Solitaire and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. For purposes of the European General Data Protection Regulation (the “GDPR”), Free Best Spider Solitaire is the “data controller” of your personal information. Free Best Spider Solitaire with the contact email address support@bestspidersolitaire.com, is our representative in the European Union. Our data protection officer can be contacted at support@bestspidersolitaire.com. This Privacy Policy applies whenever you use our “Services,” which means our games, products, services, content, www.bestspider.freefungames.xyz, and/or other domains or websites operated by us. We have prepared this Privacy Policy to help you as the user of the Services (“you” or “user”) understand how we collect, store, use, and manage information, including personal data, that you provide to us or we collect about you when you use the Service. When you use a Service, you consent to each of the collections, uses and disclosures of information (including recording and tracking) described in this Privacy Policy. Please read it carefully. Each of the Services has its own specific privacy policy, and if you download, access, or use a Service, you agree to also be bound by its specific privacy policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE ANY SERVICE. If you have questions regarding this Privacy Policy or our collection and use of personal information, please contact us as described in the Section Contact Us.

2. INFORMATION WE COLLECT ABOUT YOU

The personal information we collect or have about you will either be provided by you directly, come from other sources or will be collected from your activity on our website or applications and use of the Service as set out below. (a) Information we collect from you directly When you interact with the Service, at www.bestspider.freefungames.xyz, any other Free Best Spider Solitaire – owned website, or download the Service from a third-party app store, we will collect and store information from you directly as described below, to the extent it is available to us. (i) When you access Free Best Spider Solitaire games on a mobile device If you access the Service on your mobile telephone or other mobile device, including iPads and tablets, we collect the following information about you, to the extent it is available: Device advertiser ID; WiFi information; IP Address; and Geo-location. We will create and assign to your device an identifier that is similar to an account number. We will also collect the following information about you, to the extent it is available: Name you have associated with your device; Device type; Telephone number; Country and geo-location; (ii) Customer Support correspondence When you ask for assistance from our Customer Support team, we will collect and store: Your name and e-mail address; Information about your activity on the Service; Your user name or ID number; and Any correspondence connected to the assistance provided to you (iv) Technical and usage information When you access our Services, we collect your: WiFi information; IP Address; Geo-location; Device type; and Device advertiser ID. We also collect pseudonymous 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 refer to Ad identifiers, cookies, and similar technologies.

3. AD IDENTIFIERS, COOKIES, AND SIMILAR TECHNOLOGIES

To provide our games, websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences. How do ad identifiers, cookies, and similar technologies work? Ad identifiers are non-permanent identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. Cookies are small text files that are stored by your browser on your desktop computer or mobile device. When you access the Service, we collect certain technical information in order to (i) analyze the usage of our sites and Service; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf, such as Google Analytics, will use Log Files and other tracking technologies to collect and analyze certain types of technical information over time and across different websites following your use of the Service, including cookies, WiFi information, IP addresses, geo-location, 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, Service state and the date and time of activity on our Services, and other similar information. In some cases, we will associate this information with your user ID number for our internal use. Our Service currently does not respond to “Do Not Track” (DNT) settings in your web browser and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy. For further details regarding DNT, visit donottrack.us. We also employ other technologies including (i) web beacons, 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, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to prevent fraud, remember your in-Service preferences and speed up load times. How to adjust your preferences for interest-based advertising You can choose to prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under "privacy" or "ads" in your device's settings. You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit adobe.com and make changes at the privacy settings panel. If you disable cookies, you may lose some of the features and functionality of playing our Services, as cookies are necessary to track and enhance your Service activities. Please note that companies delivering advertisements in our Services or on our websites may also use cookies or other technologies, and those practices are subject to their own policies. We also use Google Analytics, who uses cookies to help the website analyze how users use the Service and enhance your experience when you use the Service. For more information on how Google uses this data when you visit our Site or use our Services, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/. The NAI (Network Advertising Initiative) allows for the central opting out of all its members’ cookies from a single opt-out page. If you prefer not to receive relevant advertising on web pages, please click on the following link: networkadvertising.org/choices/. If you delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice.

4. HOW WE USE THE INFORMATION WE COLLECT AND OUR LEGAL BASES FOR PROCESSING IT

In general, we collect, store and use your information to provide you with a safe, smooth, efficient, fun, and customized experience, and we use it as necessary to provide you with the Service pursuant to the Terms of Use, for our legitimate interest to understand how our users navigate our websites and apps and to improve our services, including the Service, or on the basis of your consent. In litigation or for other legal purposes involving us or a third party, we may also need to transfer your personal information to countries with a lower standard of data protection laws than is applicable in your country of residence. We will use information collected from you in any one or more of the following ways: To provide technical support and respond to user inquiries; To prevent fraud or potentially illegal activities, and enforce our Terms of Use; To deliver and target advertising; To notify users of in-Service updates; To provide in-Service leader boards and promote in-Service player achievements; To solicit input and feedback to improve Free Best Spider Solitaire group company products and services and customize your user experience; To inform users about new products or promotional offers; To improve and develop our products and Services. Marketing We may use the information we hold about you to promote our Services in any one of the following ways: Advertising on third party websites, apps, and Internet-connected devices; Showing you promotions for our other games or Services; What information do we use for marketing? We use information about you to try to make sure you only see marketing from us that might be of interest to you, including: ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies; the games you play and information about how you interact with our Services; your age, country or region, and gender; and other information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal basis to share that information with us. Opting out of direct marketing from us To disable interest-based advertising, please see How to adjust your preferences for interest based advertising. You should note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and you may see advertising for our Services, but that advertising will not be targeted using your personal information. Third Parties’ Direct Marketing 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 marketing by a third party, do not opt in to such use when you provide personal information on one of our sites. Your access to the Services will not be affected if you do not “opt in” to receive information from such third parties. Legal Bases for European Countries’ Users If you are located in a country in the European Union, the European Economic Area, or Switzerland, we explain in this Privacy Policy the legal bases which we rely upon in processing your information. Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our games, customer services, and chat functionality; Legal Obligation. This covers data used by us to comply with legal obligations, such as to maintain records relating to tax or to respond to valid legal requests for certain data; Legitimate Interests. This covers data used by us for purposes that can be reasonably expected with your use of our Services and that we do not believe are harmful to your privacy, such as analytics to understand how our users navigate our websites and apps, to keep our websites and apps safe and secure, research and optimization of our games and other Services, to provide a more personalized experience, marketing and advertising; and Consent. Where we process data based on your consent, we will ask for your explicit consent. You may withdraw consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal. While you can withdraw your consent or object to certain types of processing at any time in the ways described in this Privacy Policy, please note that if you play our games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not want us to collect any personal data about you at all, you should cease playing our games and stop using our Services.

5. SHARING OF YOUR INFORMATION

We share your personal data with our Affiliates including in the United States. Please be aware that the US and other jurisdictions may have a lower standard of data protection laws than your own jurisdiction. We will also share your personal data with third party recipients (i.e., parties other than the Free Best Spider Solitaire group of companies) including outside the European Economic Area, in the following circumstances: (a) Third party service providers We provide your information to third party recipients. These categories of recipients include: Hosting providers to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you; Email delivery providers that provide us with email delivery services; Provided you have consented, advertisers, ad exchanges and other adtechnology companies that require the data to select and serve relevant advertisements to you and others, and assist us in other marketing efforts; Data analysis providers including Google Analytics that assist us in the improvement and optimization of the websites and apps, and data analysis. We direct all such third party recipients 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 our behalf. (b) Sale or merger In the event that Free Best Spider Solitaire 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 data, to the successor organization in such transition. In such case, we will first notify you in accordance with local law requirements, if any, regarding those items of personal data that will be transferred, the name and contact details of the recipient, and inform you of how you can withdraw consent thereto. (c) Safety, security and compliance with law Your information, and the contents of all of your online communications (including without limitation chat text, voice communications and IP addresses) 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 our rights or property.

6. OUR POLICIES CONCERNING CHILDREN

Our Services (including websites, games, and applications) are not intended for children (aged 13 or such higher age as required by applicable law). We do not knowingly collect or solicit any personal data from children and we do not knowingly allow children to register for or use the Services. Children should not use our Services or send us any personal data about themselves at any time. In the event that we learn that we have inadvertently gathered personal data from children, we will take reasonable measures to promptly erase such information from our records. If you believe that we might have information from or about a child, please contact us.

7. YOUR RIGHTS AND HOW TO ACCESS, UPDATE, AND MANAGE YOUR PERSONAL INFORMATION

You can stop further use of your geo-location by visiting your device's settings for the relevant application or the "settings" page for the relevant Service. If you have additional questions about this Privacy Policy, contact us at support@bestspidersolitaire.com European Countries Users’ Rights If you are located in a country in the European Union, the European Economic Area, or Switzerland, you have certain rights in relation to the personal data we hold about you, which we detail below, and which are subject to exemptions under applicable data privacy laws. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we may require you to verify your identity before responding to any requests to exercise your rights. We will respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please send an email to support@bestspidersolitaire.com. We may decline to process requests in certain circumstances, such as where requests are manifestly unfounded or excessive or requests that jeopardize the privacy of others. (i) Deletion of your personal data In some circumstances, you may request that we erase some of the personal data we hold about you. Should you wish to have your personal information deleted, please contact us at support@bestspidersolitaire.com. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games. When we delete any information, it will be deleted from our active databases but may remain in our archives. Please note, however, we may still retain some or all of that information for other purposes such as protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form. (ii) Access and portability You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us at support@bestspidersolitaire.com and let us know that you wish to exercise your right of access and what information in particular you would like to receive. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. In some circumstances, you may request the data we process based on consent or to perform our contract with you in a structured, commonly used and machine-readable format or to request we transfer such personal data to another party. Your rights are subject to exemptions under applicable data privacy laws. If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party. We also may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property) as permitted under applicable data protection rights. (iii) Restriction of processing to storage only You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances, e.g. whilst we are considering whether it should be corrected or deleted or, based on your objection, whether we should permanently stop processing. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds for us to do so (e.g. for the defence of legal claims or for another’s protection). (iv) Objection You have the right to object to our processing of data about you other than where required to perform under the Terms of Use, e.g. in order to send you promotions and special offers marketing. You also have the right to object to our processing of data about you by emailing us at support@bestspidersolitaire.com in the following circumstances: We are processing the data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. We are processing the data on the basis of historical/scientific research or statistics and you have a particular reason to object. Your right would not apply where we have been tasked with and it is necessary for us to undertake such processing in the public interest. (v) Complaints In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at privacy@Free Best Spider Solitaire.com and we will endeavor to deal with your request. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

8. HOW LONG WE KEEP YOUR INFORMATION

We retain your personal data for the duration of your account, as long as reasonably necessary to provide you the services, and for such periods necessary to comply with the law. In the event you request deletion of your personal data in accordance with the process explained above, we will delete it as specified above. Please 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. For example, we may retain records pertaining to payments or customer service matters. If you have sent or posted content on the Service, we may not be able to delete it.

9. PRIVACY POLICIES OF LINKED SITES

Our Services may contain links to third-party 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.

10. SECURITY OF YOUR INFORMATION

We implement 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 Services and our customer databases and records, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. 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. 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 access to your Free Best Spider Solitaire Services, so be careful to keep your account information secure. If you have questions about the security of our Services, please contact us at support@bestspidersolitaire.com.

11. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

As you are contracting for the Services with Free Best Spider Solitaire, which is a US company, any information you provide to us, or that we collect through your use of the Services that is necessary to provide you the Services, will be stored, processed, and transferred within, or to, the United States. As a result, your information could be accessed by foreign governmental authorities, or otherwise, in accordance with applicable local laws. Please be aware that the US and jurisdictions other than the one in which you are located will not have the same data protection laws as your own jurisdiction. Your personal data is also processed by staff or service providers operating outside the EEA in the United States, who work for us. If we transfer your information outside of your country of residence, we will protect that information as described in this Privacy Policy.

12. 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 www.Free Best Spider Solitaire.com. We may supplement this process by placing notices in our Services and on other Free Best Spider Solitaire websites. It is your responsibility to periodically check this privacy page for updates.

13. CONTACT US

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to support@bestspidersolitaire.com. We will seek to respond to any complaints within thirty (30) Days.

REGION-SPECIFIC ADDENDUM TO PRIVACY POLICY

The following additional information applies, and supplements the above Privacy Policy, if your personal information is collected from one of the countries below:
Canada:
Personal information maintained and processed by us and third party service providers in the U.S. and other foreign jurisdictions may be subject to disclosure pursuant to a lawful access request by U.S. or foreign courts or government authorities. We will not provide your information to third parties for marketing purposes without your prior consent. For more information about our privacy practices; to access, update or correct inaccuracies in your personal information; or if you have a question or complaint about the manner in which we or our service providers treat your personal information, please contact support@bestspidersolitaire.com.
Japan:
We comply with Japanese laws and regulations, including the Act on the Protection of Personal Information (the “PIPA”). For more information on what information Google collects and how it uses this data, go to https://www.google.com/intl/ja/policies/privacy/. If you prefer not to receive relevant advertising on web pages, please follow the instruction provided by Google at https://www.google.com/intl/ja/policies/privacy/. If you delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice.