Privacy Policy

Welcome to ThunderPop’s Privacy Policy. This privacy policy (the “Policy”) applies to your download, access and/or use of the ThunderPop Game, access to our Website thunderpop.com, and any related Services.
 

We know our users don’t love long and complicated policies, but it’s important for you to read it, so we’ve tried to make this as painless to and follow as possible. If you do not agree with our Policy, do not use the Game or Website.
 

The words “ThunderPop,” “Game,” “Website,” “Services,” and any other terms that are capitalized but not defined in this Privacy Policy have the meanings in our Terms of Service. 

If you use our Services, we will collect, and process certain categories of information.

Examples of information we collect when you visit our Website include your internet protocol (IP) address, your browser type, non-precise geolocation (city, state, zip code), operating system, device identifiers, and information about ads you click. 
 

Examples of information we will collect if you choose to play the Game include your IP address, browser type, device details, cookies or other tracking data, user agent,  a unique user identifier generated by the host application, from which we may infer approximate location (for example, city, state, or ZIP code), your username/nickname, email; in-app purchase receipts (processed by Apple/Google with only transaction confirmation meta data provided to ThunderPop), gameplay, events, crash logs/diagnostics, and advertising identifiers (only after applicable consent). 
 

We also collect information about your interactions with in-Game advertising, such as impressions, clicks, and conversions. Although we may share sponsored content with you, it is important that you know we do not sell your personal information that directly identifies you, such as your name, email address or any contact information, to advertisers or third parties. The data we collect, combined with identifiers such as IP address, user agent, and unique ID, allows us to deliver targeted ads, track conversions, and analyze usage patterns across sessions. We combine this information to create profiles that enable targeted advertising, measurement, and service improvement. These processes may create persistent profiles of user behavior, which we use for ad delivery, analytics, and to enhance the overall performance of the Game. 
 

We do not collect sensitive information such as social security numbers, biometric data, or financial data. 

ThunderPop uses the personal information it collects when you use our Services for a variety of legitimate reasons. 
 

For example, ThunderPop may use personal information to improve your user experience, including the performance of its computer servers, and to administer the Services. We may also use personal information to analyze trends, track Website visits, and gather other broad demographic information to assist us in identifying user preferences. This allows us to provide, personalize, and improve content and advertising, as well as to develop analytics and reporting to support our operations.
 

We also use tracking technologies as described in the “Cookies and Tracking Technologies” section below. Certain uses of these technologies may be considered a “sale” or “sharing” of personal information under applicable U.S. state privacy laws. You may opt out of such uses as described in the “Your Privacy Rights” section.
 

We collect and use data for business purposes (referred to as “legitimate interests” in certain jurisdictions), meaning we process data in ways that are necessary and proportionate to operate, secure, and improve our Services consistent with user expectations. Where required under applicable law, we will offer you the ability to opt in or opt out, in applicable cases—for example, before activating tracking functions used for advertising or analytics.
 

Our Services do not track users when they cross to third-party websites and do not respond to Do Not Track (DNT) signals.

We use cookies and similar tracking technologies to collect and store information about how you use our Services. Cookies are small files that a game or extension places on your device for record-keeping and other purposes. We use these technologies to:
 

• Operate and secure our Services;

• Measure and analyze usage patterns;

• Deliver and personalize advertising; and

• Improve overall functionality and performance.
   

Cookies and tracking technologies may include browser cookies, web beacons, pixels, tags, and local storage objects. Certain cookies are essential to the operation of the Services, while others are used for analytics, advertising, or personalization.
 

Some uses of cookies and similar technologies may be considered a “sale” or “sharing” of personal information under applicable U.S. state privacy laws. You may opt out of such uses by following the instructions in the “Your Privacy Rights” section below.
 

Where required by law we will obtain your consent before placing non-essential cookies or using similar technologies for analytics or advertising. You may withdraw or change your consent at any time by adjusting your cookie preferences..
 

Please note that if you block or disable cookies, certain features of our Services may not function properly.

We do not share your personal information with third parties for their independent use, except in the following circumstances:
 

1. With third-party service providers, who assist us in operating, analyzing, or improving our Services. These include providers of data analysis, infrastructure, information technology, email delivery, and market-research. We share personal information with such providers only to the extent necessary for them to perform their contracted functions, and we require them to protect your information to at least the same level of privacy and security standards that we maintain. Service providers are prohibited from using personal information for any purpose other than providing technical assistance on our behalf and must notify us if they can no longer meet our data-protection expectations.
    

2. With your consent or at your direction, such as when you request or authorize a specific disclosure.
    

3. Law Enforcement, Compliance, and Protection. We may use or disclose personal information as we believe necessary or appropriate: (a) to comply with applicable laws, legal processes, or governmental requests; (b) to enforce our Terms of Service or other agreements; (c) to protect our operations, rights, privacy, safety, or property, or those of our employees, users, or others; (d) to assist in fraud detection, prevention, or investigation;  (e) to pursue available remedies or limit potential damages or (f) to manage or resolve legal disputes or claims, including with persons authorized to act on your behalf in emergencies or events beyond our control, such as natural disasters.
    

4. In aggregated or de-identified form, which we may share with our partners, service providers, advertisers, and other third parties for business purposes, such as maintaining, improving, and securing our Services, or supporting related functionality. 
    

5. With advertising or marketing partners, we may use third-parties to deliver or measure marketing messages about our own products, and to enhance your experience with our Services. These providers may collect device identifiers and usage data to provide and measure advertising. We do not permit these partners to use your personal information for their independent advertising or marketing purposes. Users can manage ad preferences through their device settings. For more information about how we use cookies and other tracking technologies—and your choices regarding advertising—please see our Cookies and Tracking Technologies section.
    

6. In connection with mergers, acquisitions, or similar corporate transactions, including the sale, transfer, or reorganization of all or a portion of our business or assets. In such cases, personal information may be among the assets transferred, and we will ensure that any successor entity continues to handle your personal information in accordance with this Policy or provides you with notice and an opportunity to exercise your rights before any material changes take effect.
    

7. A complete list of third-party data recipients is set forth at thunderpop.com/third-party-data-recipients. 
    

Any disclosures we make are limited to what is reasonably necessary for the purpose described and are subject to appropriate contractual or legal safeguards.

ThunderPop is located in the United States. Any information we collect from you will be processed in the United States.

We use commercially reasonable efforts to secure your personal information, but we cannot and do not assure that these measures will be sufficient to protect against all efforts to gain unauthorized access to the information.
 

Collected data is retained for only so long as needed to fulfill the purpose for which it was provided, or as long as is reasonably necessary for our legitimate business purposes. We may retain your information for longer periods if required by law, or in relation to legal claims.

United States: Our Services are not intended for children under 16 in the United States, and we do not knowingly collect personal information from anyone under that age. If you are under 16, please do not use the Services or provide us with any information. If we discover that we have collected personal information from a child under 16 without verified parental consent, we will delete it. Parents or guardians who believe we may have such information should contact us immediately.
 

Brazil (LGPD Art. 14): Our Services are not intended for children under the age of 12 if you live in Brazil. We do not target or knowingly process such data in the Services. If you are under 12, please do not use our Services or provide us with any information. If we discover that we have collected personal information from a child under 12 without verified specific and prominent parental consent, we will delete it. Parents or guardians who believe we may have such information should contact us immediately. 
 

Indonesia (PDPL): If you live in Indonesia or are a citizen of Indonesia, we do not target children and if you are under the age of 18, if discovered, we will delete any personal data collected without specific parental/guardian approval. Parents or guardians who believe we may have such information should contact us immediately.

You have rights and choices regarding your personal information, which may vary depending on where you live. To exercise your privacy rights, including the rights to access, delete, correct, and limit personal information, please submit a request at privacy@thunderpop.com. If you would like to continue to opt out of the sharing of your personal information, you may submit a request at privacy@thunderpop.com.
 

Your privacy rights may include the right to:
 

• Access – depending on applicable laws, request that we disclose the categories and specific pieces of personal information we collect, use, disclose, and share, as well as the business purposes for which we collect and use that information;
   

• Correction – request that we correct any personal information that is inaccurate or outdated;
   

• Deletion – request that we delete personal information we maintain about you, subject to applicable legal limitations;
   

• Portability – if it is reasonable under applicable laws for us to do so, request a copy of your data in a structured, machine-readable format and, in certain cases, ask that we transmit it to another data controller;
   

• Limit, restrict, object to, or opt out of processing or selling – under certain applicable laws, you may request that we stop or limit how we process your data, including limiting the use of sensitive personal information, and opt out of the selling of your personal information. Specifically, under California law, you also have the right to direct us not to “share” your personal information for targeted or cross-context behavioral advertising purposes at any time. In other U.S. states, similar opt-out rights may apply where our activities fall within the concept of a “sale” of personal information. Under certain applicable European laws, you may also request that processing be limited while we respond to one of your other requests; and
   

• Be free from discrimination for exercising your privacy rights.
   

If you have provided personal data based on consent, you may withdraw your consent at any time. We will consider and process your request within a reasonable time period as required by applicable law.
 

Before processing or granting any request, we are required to confirm that the right being exercised is available under applicable law, as certain rights may apply only to residents of specific jurisdictions. Only you—or a person authorized to act on your behalf—may submit a verifiable request related to your personal information. To ensure security, we must verify your identity and confirm the personal information associated with you, which may require additional details depending on the type of request. We may use a third-party verification service to assist in this process.

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We cannot process or respond to a request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Depending on the jurisdiction, limitations may apply to how often access requests can be submitted within a 12-month period, and we may have the right to decline requests that are unfounded, excessive, or otherwise not considered reasonable within that jurisdiction’s standards. For example, under California law you may only make a verifiable consumer request for Access twice within a 12-month period. If we deny your request, we will explain the reason and provide information about any rights to appeal. We strive to respond within the timeframes required by applicable law.

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If you have opted in to marketing emails, use the unsubscribe link included at the bottom of any marketing or promotional email we send you to opt out. Please note that even after you unsubscribe, you may still receive transactional or service-related messages related to your account or our ongoing business relationship.

Certain states may allow residents to appeal a denial of a privacy-related request. If we decline to process your request, you may have a right to appeal by emailing privacy@thunderpop.com. We may reject your request for appeal if the state in which you reside does not allow a right to appeal.

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If you wish to make a complaint about how we process your personal data, please contact us at privacy@thunderpop.com. We take all complaints seriously and aim to resolve them with respect. Although we believe we can address most complaints with you directly, you may also choose to file a complaint with the relevant data protection authority.

If you are physically located in Brazil, you may have these LGPD-specific rights/notices in addition to the rights detailed in the preceding paragraphs.: 
 

• Confirmation of processing: the right to confirm whether we process your personal data. 
   

• Information on shared use: the right to know with whom (public/private) entities we share personal data and for what purpose. 
   

• Anonymization/blocking/deletion of unnecessary or excessive data: where data is unnecessary, excessive or processed in non-compliance. 
   

• Automated decisions: the right to request a review of decisions based exclusively on automated processing (profiling, credit scoring, etc.) that impact your interests. 
   

• Consent specifics: the right to revoke consent at any time, and to be informed of the possibility and consequences of refusing consent (e.g. without an email we can’t create an account). 
   

• Language & Contacts: you may submit requests in English to privacy@thunderpop.com.

If you are physically located in Indonesia or are an Indonesian citizen, you have these PDPL specific rights in addition to the rights detailed in the preceding paragraphs: 
 

• Right to information (transparency): to clear information about our identity, legal basis, purposes, categories of data, and recipients when we process your data.
   

• Access & Copy: to know whether we process your data and to receive a copy in a commonly used, machine-readable format (where feasible).
   

• Automated decisions/profiling: to object to decisions based solely on automated processing (including profiling) that have legal or similarly significant effects, and to request human review where applicable.
   

• Complaints and Redress: to lodge a complaint with the competent Indonesian supervisor authority (once designated/operational) and to seek compensation for violations.  
   

Language & Process: you may submit a request in English to privacy@thunderpop.com; we will verify identity and respond within PDP timeframes.

We may revise or update this Policy from time to time. If we make significant changes to how we handle personal information, we will post changes to the Policy on our site and change the date on the top of this page. Your use of our Services following the posting of changes on our website will constitute your consent to the changes.  If material changes are made, we will provide additional notice in advance (e.g., a disclaimer on our website).

If you have any questions about our privacy practices, you can reach out to us at privacy@thunderpop.com. Account-related or technical questions concerning the operation of the Game should be sent to support@thunderpop.com. 
 

 Thanks for playing ThunderPop!