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Eight days ago, I wrote a post about Absolute Poker’s ridiculously non-random Keno, which detailed a pathetically incompetent mistake that they had made (or perhaps that an outside contractor, Betsoft Gaming, had made that they’d completely failed to notice). It also explained that their official explanation was a lie and that over five months had gone by without compensation or a better explanation. (I highly suggest reading that post before this one. Otherwise, you’ll have absolutely no clue what I’m talking about. Plus, it’s worth the read.)

Well, I’ve been paid back. At 2:00 today, I got this e-mail from AP (I bolded the important part):

Dear Noah,

Collect additional coins every four hours and complete achievements to get even more!Absolute Keno is one of the best looking and most exciting casino games out there, and doesn't require any prior.

As a valued customer and Keno player at our site, we want to update you on an issue we were made aware of that suggested the Keno game we offered to players was operating in a non-random way.

Our early analysis of this claim stated that there was a flaw specific to the game logic in ‘ten play’ only on Traditional Keno and no confirmed issue with the Random Number Generator (RNG). Upon notice of the flaw, we contacted our third party software provider of Keno, Betsoft Gaming (BSG) for a more comprehensive investigation and subsequently removed all Keno games from our site until the investigation was complete and all corrective actions taken.

Our joint investigations with BSG confirmed that while the RNG for Keno was functioning properly, it was selecting from a pre-existing data set that was not as extensive as it should have been. The results were in turn random, but from a limited data set rather than from the full data set from which RNG is expected to choose.

Absolute Keno is one of the most exciting and best looking casino games out there. If you love lotto, bingo or instant style games you’ll love Absolute Keno. Absolute Keno is a fun and entertaining break from other casino games like poker, slots, craps, roulette or blackjack, or from state lotto games like Powerball or Mega Millions. Free Online Keno is a very popular game in casinos around the world, both online and physical. It’s like a lottery or bingo, game with simple rules where players guess which numbers will be drawn at random and get paid based on how many numbers you guess correctly. Absolute Bingo is a no-wait bingo game that has just been updated with better graphics, new rooms and additional bingo patterns! Collect additional coins every four hours and complete achievements to get even more. See if you can win before all the bingos are called! You’ll only need to step into Red Rock’s Keno Lounge to see why it’s widely regarded as the absolute best in Las Vegas. It hosts 20 seats, four writer stations, automatic ball drawing, and Jumbo Keno as a linked progressive on 6, 7, 8, and 9 spot tickets.

While the issue stemmed from our third party software provider, we accept responsibility for offering our players a Keno game that had the described issue. Therefore refunds have been issued to all Keno players of ‘five Play’, ’ten Play’ and all Traditional Keno during the period those games were offered . Any net loss you experienced while playing Keno with us, no matter how small has been credited to your account. [emphasis mine]

Keno Software For Pc

Your account has been credited with:

Total Amount: $12.70

We wish to offer our sincere apologies for any confusion or frustration this issue may have caused you, and we thank you for your patience while we have endeavored to correct this situation. We also want to restate our commitment to providing a safe, secure and fair gaming environment for our players.

If you have any questions about your refund, please write to us at [removed so they don’t get spammed]

Thank you for your understanding, support and continued confidence in our game offerings.

The Absolute Poker Team

I’ve checked with a few people, and everyone seems to have been repaid a reasonable amount. (Obviously, if you haven’t been repaid, please get in contact with me.) I got my $12.70 from my degen Keno investigation, so that’s cool.

They calculated payments fairly enough. Even though their initial statement said that the problem was only with the ’10 play’ feature (which was a lie), they say they’ve repaid for all play. They say they used net losses from all those games, which I think is perfectly reasonable. I didn’t keep track of how much I lost while investigating this, but the $12.70 seems about right.

So, they deserve credit for eventually repaying their customers.

I’m quite tempted to end my post there because I hate to attack them in a post that I started writing because they repaid their customers. They should be thanked for repaying their customers, and they should certainly not be discouraged from doing the right thing in the future by a fear that any action that they take will lead to negative press. I swear that had they handled any part of this decently, I would have been much much more forgiving given that they did repay customers in the end. But, they screwed up so much here and revealed so much incompetence, negligence, and maliciousness that I just can’t in good conscience bury the hatchet.

First, Remember How We Got Here

The only reason that they needed to repay their customers is because they had this rigged game up on their site. That’s obviously something that should never happen.

And of course, they took forever to repay. Five-and-a-half months after myself and Thomas Bakker made this public, they’ve just now gotten around to repaying. That also should never happen. And, while I obviously can’t prove that they only decided to repay because I made a stink about it and got them some bad publicity, the fact that they didn’t repay for so long definitely makes it look like they weren’t planning on repaying. (Their statement, as relayed to me by Joe Sebok, that they had been waiting for BSG to provide data is obviously ridiculous. The money came from AP player accounts to AP’s company coffers. They of course have an internal transaction history of all of that.)

(I don’t know how much they ended up repaying, but I think it’s pretty safe to assume that it’s a relatively insignificant amount for such a large company. For example, Joe Sebok said at one point that he “believed” it was under $30k. I’m not sure if that makes it better or worse that they’ve taken so long to repay it.)

Their Explanation Reveals Incredible Incompetence and Sketchiness

Much more importantly, their explanation is still a lie, and it shows an amazing level of incompetence. See this part of the e-mail:

Our joint investigations with BSG confirmed that while the RNG for Keno was functioning properly, it was selecting from a pre-existing data set that was not as extensive as it should have been. The results were in turn random, but from a limited data set rather than from the full data set from which RNG is expected to choose.

Translation: They’re saying that they had generated some set of random spins of Keno (or maybe random sets of ten spins for their ’10 play’ feature) and then just randomly selected from them.

First of all, that is not how a casino game is supposed to run. You don’t randomly select from some results that you generated earlier. You randomly select from all possibilities with the proper weightings. That should be completely obvious. And, doing it the way that they say has a lot of flaws. In Keno, it would have the one major flaw that a customer’s win distribution isn’t the win distribution expected from the game; it’s whatever win distribution the game designers got from their inital generated set. That’s wrong already because customers are signing up to play a random game of Keno and not a game of “let’s pick randomly from the results that the game designers got.”

So, yeah, that’s bad. But, use of this method gets pretty sketchy when you consider that sets can be regenerated: Suppose that the game designers generated a set that happened to result in worse-than-expected results for the house. That obviously happens about half the time, and if AP notices this and AP decides to “correct” this when it happens, that would constitute rigging of the game in the houses favor–The game would always be slanted, but never significantly in the player’s favor. The really terrifying thing about this is that the game could be rigged in the house’s favor as a result of nothing more than an innocent and incompetent employee thinking “Hmmm… This dataset isn’t good. I’m going to generate another one.”

Plus, this would be essentially undetectable. Even if we could somehow get a massive sample of data (or even the originally generated set itself), we wouldn’t be able to distinguish between a randomly generated dataset that happened to give the house an advantage and one that was chosen (either due to maliciousness or incompetence) specifically because it gave a house advantage.

How big of a deal this is obviously depends on how extensive the dataset was, since larger datasets are much less likely to be slanted much in any direction. This quote from the e-mail might be relevant: “a pre-existing data set that was not as extensive as it should have been.” So, while I don’t know specifically that this happened in this case (Over the small sample where I played this game and actually recorded my results, I actually ran better than expected), this method of generating data requires that AP’s employees be both extremely competent and of very high integrity or else their games could be easily rigged in the house’s favor. That would be a ridiculous amount of trust to put in any company. It’s absurd for AP to expect that of us (though, to be fair, they may not have realized how flawed this was).

In other words, their current official explanation is “We were trying to set up a game in a way that wouldn’t provide our customers with the game that they wanted and could allow for easy (and even accidental) manipulation by our employees, but we didn’t do it right.”

This actually isn’t the only example of AP using this methodology.

In fact (and I can’t help but bring this up, because Jesus I can’t believe AP is actually admitting to this publicly), this is not the only instance of Cereus using this incredibly stupid and sketchy methodology. (Sorry for the vagueness. I’m sitting on a fairly big story, but I just can’t tell it until I’ve fleshed out exactly what happened. Suffice it to say that the people who work for Cereus who are reading this know what I’m talking about, and you will soon.)

(I should say that I’m using AP here as a catch-all for AP, BSG, and TST. It may well be the case that Betsoft Gaming made this ridiculous game and not AP. So some of the things that I directly attribute to Absolute Poker could have been done by BSG instead. However, AP put this on their web site so they’re responsible for it. They’re a massive online gambling company, so they should be expected to know how these things should be run and to check that they are run correctly before putting them on their web site. I sympathize in general with the unfortunate consequences of hiring incompetent outside contractors, but AP could have done any tiny amount of due diligence and discovered that something was up. Hell, this was discovered by someone who was just playing the game casually and had no access to anything behind the scenes.

And, of couse, the company Technical Systems Testing that certified this game as random is obviously just a rubber stamp. There’s no way that anyone could be hired for the explicit job of checking the randomness of this game and conclude that it was okay unless they simply didn’t do what they say they did.)

Also, It’s a Lie

So, yeah, that explanation–the one that goes “We were trying to do things in the dumbest and sketchiest way possible, but we couldn’t even get that right”–That’s not true. How do I know? Because it’s completely inconsistent with what happened.

The flaw that I was shown and that Thomas and I presented to you in our original video showed a very clear pattern: When you picked five numbers and ran ten consecutive spins with the ’10 play’ feature, there was an absurdly high likelihood (86%) that the nth and (n+5)th spin would hit 3 numbers and no other round would pay. (That makes a lot more sense when you actually watch the video, which is the first one in my previous post on the topic.)

So AP is now claiming that they randomly generated a dataset that had those absurdly predictable results? That doesn’t explain anything. All it does is leads to the question “Why did your ‘randomly’ generated dataset have such an incredibly unlikely pattern in it?” I already did the math in my original 2p2 post from 5 months ago that showed that over a sample size of only 50, the odds of seeing such an absurd pattern are about one in 10^45. So, unless their “pre-existing data set that was not as extensive as it should have been” actually had less than 50 data points in it, this just isn’t true.

(I acknowledge that this quasi-mathematical argument is slightly hand-wavy and disingenuous, but I’m hoping the fellow nerds in the audience will give me a pass here. The point is clear, and the actual math is tedious. I just don’t have the time to dot every i right now.)

In fact, there’s tons of other evidence that their new explanation is a lie (both things that I made public five months ago and things that I’m keeping to myself for now). But, AP has shown that they’re willing to lie about this, and they’ve also shown that they’re very bad at it. Therefore, I will not make it easier to lie by spelling out exactly which explanations make sense and which don’t. They can feel free to try again, or they can just actually say what happened.

More likely, they’ll just drop it now that they’ve repaid.

Policy Effective: Jan 1 2020

This Privacy Policy describes the personal data we collect and why, how we use that data and your rights.

This Privacy Policy applies to Absolute Games' games, websites and related services, which we here collectively call the “Service”. This Privacy Policy may be periodically updated. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

For purposes of data protection laws, Absolute Games LLC. is the “data controller” of your personal information. We will refer to countries in the European Union (EU) and the European Economic Area (EEA) and Switzerland collectively as the “European Countries” in this Privacy Policy.

1. Contact Us

If you have any questions about data protection, or if you have any requests for resolving issues with your personal data, please contact us inside the game as that is usually the fastest channel of response.
Absolute Games
375 North Stephanie Street, Building 17
Keno Las Vegas, NV 89014
email: support@absolutegames.com

2. The Data We Collect

A. Data you provide us:
  • Contact information (such as name and email address)
  • Your messages to the customer support
  • Other data you choose to give us (such as data to transfer progress or identify a lost account)
B. Data we collect automatically:
  • Data about your account and game progress
  • Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
  • Data about your device, such as device name and operating system, browser type and language
  • Data we collect with cookies and similar technologies (see more below)
  • General location data
  • Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service
C. Data we collect from our partners:
  • Data we receive if you link a third party tool with the Service (such as Apple, Amazon, Facebook or Google)
  • Demographic data (such as to determine the coarse location of your IP address)
  • Data to fight fraud (such as refund abuse in games or click fraud in advertising)
  • Data from platforms that the games run on (such as to verify payment)
  • Data for advertising and analytics purposes, so we can provide you a better Service

3. Why Do We Collect Your Data

A. To make the Service work
We process data necessary to:
  • Create accounts and allow you to play our games and use our Service
  • Operate the Service
  • Verify and confirm payments
  • Provide and deliver products and services you request
  • Send you Service-related communications
B. To make the Service better
To provide an excellent Service for our players, we collect and process necessary data to:
  • Create and update player profiles
  • Improve the Service and player experience
  • Provide social features as part of the Service
  • Customize your Service experience
  • Respond to your comments and questions and provide player support
  • Provide you offers in the Service as well as in other websites and services, and by email
  • Send you related information, such as updates, security alerts, and support messages
C. To show ads
To show you personalized advertisements in the Service as well as in other websites and services (including email) we process necessary data to:
  • Track the content you access in connection with the Service and your online behavior
  • Deliver, target and improve our advertising and the Service
  • For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.
D. To protect
Making sure the Service is fun and fair is important to us. In order to keep the Service protected, to fight fraud and ensure acceptable use otherwise, we process necessary data to:
  • Analyze and monitor use of the Service and its social features
  • Take action against fraudulent or misbehaving players
D. To verify
In all of the above cases and purposes, we may verify, categorize and store all collected data.

4. Who Can See Your Data

Apart from Absolute Games, your data can be accessed by others in the following situations:
A. Other Users
Keno Other players and users may read the messages you have posted publicly to third party services.
B. Partners Working For Absolute Games Keno
Absolute Games has partners to perform services for us. These partners process your data only at and according to Absolute Games's instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.
C. Other companies and public authorities

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In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
D. Advertising
The Service may contain advertisements from “Third-Party Services,” meaning companies other than Absolute Games may link to their own websites, online services, or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.

5. International Data Transfer

IMPORTANT: When you use our Services, your personal information may be sent to the United States and possibly other countries.
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

6. Your Rights and Options

A. Opt-out of targeted advertising.
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting 'limit ad tracking' (Apple iOS) or 'opt-out of interest based ads' (Android).
B. Access the personal data we hold about you
If you request, we will provide you a copy of your personal data in an electronic format.
C. Your other rights.
You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by not using the Service. To contact us, please send us a message inside the game, or to support@absolutegames.com.
We will respond to all requests within a reasonable timeframe. You may also contact your local data protection authority for unresolved complaints.

7. California Privacy Rights

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information
When California Consumers access the Absolute Games websites, purchase Absolute Games products, contact Absolute Games, visit one of our physical locations, seek employment with Absolute Games, or become a Absolute Games employee, we collect the following Personal Information.

Categories of consumer’s Personal Information collectedBusiness or commercial purposes for which the information was collectedCategories of sources from which that information was collectedCategories of third parties with whom the business shares personal informationPersonal Information disclosed or sold to third parties for a business or commercial purpose in the preceding 12 months
Identifiers
  • Alias
  • Email Address
  • Account Name
  • Unique Personal Identifier
  • Online Identifier
  • To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute;
  • To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute;
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To ensure minors do not unlawfully enter our facilities;
  • To provide you with the products and services you request, view, engage with, or purchase;
  • To communicate with you regarding your account or transactions with us;
  • To send you offers and promotions for our products and services;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies.
This information is collected directly from you. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Commercial Information
  • Products or service purchased, obtained or considered
  • Purchasing or consuming histories or tendencies
  • To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute;
  • To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute;
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To provide you with the products and services you request, view, engage with, or purchase;
  • To communicate with you regarding your account or transactions with us;
  • To send you offers and promotions for our products and services;
  • To provide you with targeted advertising based on your activity on our sites;
  • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies
This information is collected directly from you or by logging our interactions with you. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Internet or Electronic Network Activity Information
  • Browsing history
  • Search history
  • Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
  • Internet Protocol address
  • Device ID
  • Cookies
  • Unique Personal Identifier
  • Online Identifier
  • Beacons
  • Pixel Tags
  • Mobile Ad Identifiers
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To provide you with targeted advertising based on your activity on our sites;
  • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies
We collect your internet or other electronic network activity information from your interactions with our website. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
  • Geolocation Data
    • Location information
    • Device location information
    • To enforce the Terms of Service or Use of any of our websites, applications or services;
    • To prevent fraud;
    • To provide you with targeted advertising based on your activity on our sites;
    • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
    • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
    • To debug, to identify and repair errors that impair existing intended functionality; and
    • To investigate and prevent activities that may violate our policies
    We collect your geolocation information from your interactions with our website. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
    • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

    In the preceding 12 months, we have not sold Personal Information about consumers.

    In the preceding 12 months, we have not sold Personal Information about minors.

    Individual Rights
    Right to Know About Personal Information Collected, Disclosed, or Sold
    You have the right to request that Absolute Games disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

    Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:

    • Category of personal information collected,
    • Categories of sources from which that information was collected,
    • The business or commercial purpose(s) for which the information was collected,
    • The categories of third parties to whom Absolute Games sold or disclosed the category of personal information for a business purpose, and
    • The business or commercial purpose for which Absolute Games sold or disclosed the category of personal information.

    Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:

    • Specific pieces of Personal Information collected about you.

    Absolute Games does not sell any Personal Information of California consumers. This information will be provided to you free of charge, unless Absolute Games determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

    Right of Deletion
    You have the right to request that Absolute Games and our service providers delete any Personal Information about yourself that Absolute Games has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

    Submitting Requests
    You may submit a request through a webform available by emailing us at ccpa@absolutegames.com or send us a request to our support center inside our game.

    Verifying Requests
    Absolute Games provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. Absolute Games must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. Absolute Games reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

    Authorized Agent
    You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Absolute Games requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Absolute Games. Failure to do so may result in Absolute Games denying your request.

    Right to Equal Service
    Absolute Games will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

    • Denying goods or services to you.
    • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
    • Providing a different level or quality of goods or services to you.
    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

    8. California Privacy Rights: Shine the Light

    Under California’s “Shine the Light” law, California residents who provide certain personal information in connection with obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

    To obtain this information please contact us at the information provided below. We will provide the requested information to you pursuant to the contact information provided to us.

    Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

    9. How Do We Protect Your Data

    A. Security Safeguards
    In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
    B. Data retention
    We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

    10. Age Limits

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    Generally speaking, most of our Services are not intended for children under the age of 13 (or under 16 for children located in the European Countries) (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.
    Though our Services do not target Children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as Children in our age-gate on such Services, if we allow Children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA, or obtain legally valid parental consent.

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    If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16, please contact us.

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