Avia Games Privacy Policy

Last Updated: November 10, 2025

AviaGames, Inc. (“AviaGames”, “we”, “us”, “our”) provides interactive skill-based games. Avia Games respects and values your privacy. This Privacy Policy (or “Privacy Notice”) is designed to help the individuals engaging with us from the United States understand how we collect, use, process, and share your personal information, and to inform you of how to exercise your privacy rights.

If you reside in one of the following regions, please refer to the dedicated Privacy Notice that applies to you:

United Kingdom and European Union: Avia Games EU and UK Privacy Policy (Available in: English | German | Danish)

Australia: Avia Games Australia Privacy Policy

Canada: Avia Games Canada Privacy Policy

Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act and California Privacy Rights Act of 2020 (“CCPA/CPRA”), please see Annex A – Supplemental CCPA/CPRA Privacy Notice.

Scope. This Privacy Notice applies to personal information processed by us, including on our websites, games, applications (including, but not limited to 8 Ball Strike: Win Real Cash, Bingo Bliss, Bingo Clash, Bingo Tour, Blockolot, Bubble Buzz, Pocket7Games, Solitaire Clash, Solitaire Clash infinite, Solitaire Slam, Solitaire Venture) and all other online or offline products, services, and offerings we may provide in the future. To make this Privacy Policy easier to read, our websites, mobile applications, games, and other offerings are collectively called the “Services.”

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

• Account Creation. To access certain parts of our Services, you may need to create a profile (your “AviaGames Account”). When you create an AviaGames Account for use with our Services, we may collect username, password, country location, and email address. You may also have the option to add a short description about yourself, or a profile image, your username, country location, profile image, and description about yourself, which will be visible to other Users.
  • You can also access some of our Services as a guest, without creating an AviaGames Account. If you use our Services without creating or logging into an AviaGames Account, we will still collect the personal data described in “Information Collected Automatically” below associated with your device identifiers and may also collect include your name and payment information (as described in the “Payment Information” section immediately below), device information, and location. We may connect this information with your AviaGames Account, if you have one, or if you create an AviaGames Account at a later date.
  • Date of Birth: to play cash games, you will need to provide your date of birth, which will be associated with your account.
• Payment and Financial Account Information. This may includes bank account, payment card details, and other payment information associated with a transaction made by you in respect of our services, details about payments to and from you and other details of products and services you have purchased from us, in-service wallet account-related information and any withdrawal requests made by you, and details of the third-party payment system you use. We use this information to process your purchases, deposits, withdrawals and other financial transaction requests in our Games, Products and Services. We may also process certain information to identify and prevent fraud or other illegal activities.
  • In addition to the above, we also partner with third-party payment processing companies who process your transactions (which may include PayPal, Apple Pay, Venmo, etc.), and they may directly collect your first and last name, date of birth, email address, physical address, credit and debit card information, government-issued identification, preferred currency, bank statements, IP address, phone number, and other personal or financial information as needed to process your transaction, verify your identity, and confirm you are legally eligible to make the transactions relates to your account. Your direct interactions with such third-party payment service providers may be governed by their terms of service and privacy policies.
  • We generally do not collect biometric information. However, in individual cases where there is an actual suspicion of fraud or other illegal activities and when the total deposit or withdrawal amount exceeds a certain threshold (e.g. when your total withdrawal amount has reached at least 3000USD, we may update this amount threshold from time to time), you will be asked to upload a copy of your government issued ID documentation such as your passport or driving license (both front page and back page) and a Selfie of yourself. We process such data to verify your identity. We will use and share the information with our third-party service providers (e.g. Jumio) to verify the authenticity of your government issued ID, recognize the faces both in the government issued id and the selfie you provided for matching purposes, as well as recognize the liveness in the selfie provided. Your submission of a photo and government-issued ID to our service provider may be subject to that service provider’s privacy policy, and you should review that privacy policy before submitting any personal information.
• Your Communications with Us. We and our service providers may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us.
• Text Opt-In Compliant Privacy Policy. Our text messaging may consist of collecting names and phone numbers for employee text message communication, as well as from users who have opted in to receive SMS messages from AviaGames Inc. These messages are limited to transactional, game and account-related communications, which may include verification codes, deposit and withdrawal confirmations, account and balance updates, credits added to your account, customer support responses, service updates, and security alerts.
  Message frequency may vary. Message and data rates may apply.
  You may opt out at any time by replying STOP to any message. You may reply HELP for assistance or contact privacy@aviagames.com.
  We do not sell or share mobile phone numbers or SMS opt-in data with third parties for marketing or promotional purposes. Mobile phone numbers and SMS consent are used solely by AviaGames and its authorized service providers to deliver the account-related messaging services you have requested.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). AviaGames also may collect, use, store, transmit and publicly display statistical data regarding your game play (e.g., scores, rankings, and achievements). Any information you provide using the public sharing features of the Services (referred to in this Policy as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution and discretion before revealing any information that may identify you in the real world to other users.
• Sweepstakes, Tournaments, Competitions, Contests, or other Events. We may collect personal information you provide for any sweepstakes, tournaments, competitions, contests, or other events that we offer (e.g., name, email address, date of birth). In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

B. Personal Information Collected Automatically

• Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address or precise geo-location information if enabled on your mobile device).
• Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit or emails that you open from us, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
  • Telemetry. When you play our games, we may collect statistics and other information about how you use the Services. This may include information about gameplay, game server usage, game device usage, system interactions, friends you connect with through our Services, and other information associated with your AviaGames Account. We might also record your gameplay, (including your button inputs), and replay it to you or other Users or use it to match you with other player(s), improve our Services and prevent fraud. We may also use records of your in-game behavior and skill levels to match you with other players or the recorded gameplay of other player(s).
  • Crash Reports. We may collect usage details about when you launch our games, when and how long you play each game, and detailed crash reports, which may contain information about the hardware or device you play our games on.
• Cookies and Other Technologies. We, as well as third parties, may use cookies, pixel tags, and other tracking technologies (“Technologies”) to automatically collect personal information through your use of the Services.
  • Cookies. Cookies are small text files stored in device browsers.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

• Site Operations. These Technologies are used to provide Services functionality, for security and fraud prevention services, and other purposes we deem necessary to provide and maintain the Services.
• Analytics. These Technologies are used to assess the performance of our Services, and to collect analytics about use of the Services.
• Functionality. These Technologies are used to offer functionality on our Services, such as to identify you when you sign in or to keep track of your specified preferences, interests, or past items viewed.
• Sale, Sharing and Targeted Advertising. These Technologies are used for targeted advertising, and to deliver content, including ads tailored to your interests on our Services or on third-party websites and services. Some of these Technologies may in volve a “sale” or “sharing” (for targeted advertising) in some jurisdictions.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Third Party Sources

Third-Party Websites, Applications, or Platforms. To access some of our Services, you may have the option to link an account on a third-party website, application, or platform, such as Google, Facebook, and Apple (“Third-Party Platforms”) with the Services. Third-Party Platforms are not controlled by us, and their collection and usage of personal data is subject to their respective privacy policies. We may obtain additional information about you from the Third-Party Platforms, depending on your privacy settings.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information with people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

ID Verification Partners. We may obtain personal information about you from credit bureaus and identity verification partners.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

B. Administrative Purposes

C. Marketing

We may engage third-party advertising partners to promote our Services based on your interactions with our Services. Under certain state privacy laws (such as those in California, Colorado, and Virginia), this activity may be considered a 'sale' or 'sharing' of personal information, or 'targeted advertising'.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

E. Automated Decision Making

If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

• Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with identity verification, hosting, customer service, analytics, marketing services, IT support, and related services. We may provide your name and address to our third-party vendor who issues digital and paper checks on our behalf, so we can send you a check for your winnings. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.
• Some of the service providers we may use include:
  • Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.
• Other Users You Share or Interact With. The Services may allow our users to share personal information or interact with other users of the Services, such as your profile or User Content (which may be viewed by other users).
• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).
• Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
• Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
• Affiliates. We may share your personal information with our corporate affiliates.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.”

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties:

• if we are required to do so to comply with our legal or regulatory requirements; or
• if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).
• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Technologies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to provide or confirm additional information, such as your name, email address and/or the unique identifier number (UID) associated with your account.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below.

You may also submit the request through “Do Not Sell or Share My Personal Information” link found at the bottom of our website.

We will process such requests in accordance with applicable laws.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. CHILDREN’S INFORMATION

The Services are not directed to children under 18, and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s AviaGames Account if applicable.

9. OTHER PROVISIONS

Sensitive Personal Information. We do not generally require you to disclose any sensitive personal information (for example, details of race, religious belief, or sexual orientation) to us, unless we have a legitimate ground to do so, such as it is necessary for us to provide the Services, perform a contract with you, or fulfill a legal obligation. If you do provide us with sensitive personal information for any reason, you consent to us collecting that information and then using and disclosing that information for the purpose for which you disclosed it to us.

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services or the Services may allow you to interact with third-party services that are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the third-party’s actions or omissions, including but not limited to their privacy practices, content of such other websites or applications, and errors or bugs in their software. Providing personal information to third-party websites or applications is at your own risk.

10. CONTACT US

AviaGames, Inc. is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please submit a privacy request using our online Data Subject Request Form, or contact us at: privacy@aviagames.com.

ANNEX A – SUPPLEMENTAL CCPA/CPRA PRIVACY NOTICE

This Supplemental CCPA/CPRA Privacy Notice supplements our Privacy Notice and only applies to our processing of personal information that is subject to the CCPA/CPRA.

Notice at Collection

• Personal Information Collected. See the section of this Supplemental CCPA/CPRA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of personal information which may be collected. If we have previously collected personal information in the past 12 months, we may collect that personal information from you.
• Uses of Personal Information. See the section of this Supplemental CCPA/CPRA Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use personal information.
• Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? Yes. See the section of this Supplemental CCPA/CPRA Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. If we have previously “sold” personal information or “shared” personal information for “cross-context behavioral advertising” in the past 12 months, we may “sell” or “share” that personal information if collected from you. See the section of this Supplemental CCPA/CPRA Privacy Notice titled “Right to Opt Out of ‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising’ for instructions on how to opt-out of these activities.
• How Long is Personal Information Retained For? To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
• Additional Information. For more information on our privacy practices, please review this Supplemental CCPA/CPRA Privacy Notice and our Privacy Notice. Importantly, the section of our Privacy Notice titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA/CPRA.

CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources as are describe in our Privacy Notice.

Overview of Personal Information Collected, Disclosed, sold, and/or shared

The CCPA/CPRA provides California residents with the right to know what categories of personal information AviaGames has collected about them, whether AviaGames disclosed that personal information for a business purpose (e.g., to a service provider), whether AviaGames “sold” that personal information, and whether AviaGames “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

USES OF PERSONAL INFORMATION

• Providing the Services as further described in our Privacy Notice;
• Processing for administrative purposes as further described in our Privacy Notice;
• Processing for marketing purposes as further described in our Privacy Notice;
• Processing with your consent or direction as further described in our Privacy Notice;
• Processing to carry out automated decision making as further described in our Privacy Notice;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with AviaGames;
• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar Services;
• Providing advertising and marketing services;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by AviaGames, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by AviaGames.

RIGHT TO OPT Out of “Sales” of Personal Information and/or “Sharing” for “Cross-Context Behavioral Advertising”

We may “sell” your personal information or “share” your personal information for “cross-contextual behavioral advertising” to provide you with “cross-context behavioral advertising” about our products and services, as well as to measure and analyze performance, improve the services we provide, and detect illegal or harmful activities.

California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by clicking on the “Do Not Sell or Share My Personal Information” link found at the bottom of our website.

Disclosure Regarding Individuals Under the Age of 16

AviaGames does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. AviaGames does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

Disclosure Regarding Opt-Out Preference Signals

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data "sales" as defined under certain laws. In certain territories, when we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law. If your browser supports it, you can turn on the GPC to opt-out of the “sale” or “sharing” of your personal information.

Disclosure Regarding Sensitive Personal Information

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at AviaGames and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• For short-term, transient use.
• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by AviaGames, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by AviaGames.
• For purposes that do not infer characteristics about individuals.

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA/CPRA.