Grand Cru Games LLC Privacy Policy

Last Updated: January 7, 2020

Grand Cru Games LLC Inc. ("Grand Cru Games", "we" or "us") is providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of all users ("you," "users" or "Data Subjects") information that we receive through our software, games, mobile applications, products , websites (including domains owned, operated or controlled by Grand Cru Games) and services, features, and contests that we may provide to you ("Products") and from third parties. This Privacy Policy does not apply to any third-party websites, products, services or applications, even if they are accessible through our Products.

Before you use or submit any information through or in connection with the Products, please carefully review this Privacy Policy. When you use any of our Products, you consent to the collection, use and disclosure of your information as described in this Privacy Policy. Irrespective of which country you reside in or supply information from, you authorize Grand Cru Games to use your information in the United States and any other country where Grand Cru Games operates. If you have any concerns about providing data to us or having it used in any manner permitted in this Privacy Policy, you should not use our Products.

We may revise our Privacy Policy at any time and in our sole discretion. The most current version of our Privacy Policy will govern our use of your information and will be posted on our website. If the revision, in our sole discretion, is material, we will send you a notification or post a notice on our website. By continuing to use our Products after those revisions become effective, you agree to be bound by the revised Privacy Policy.

How We Collect Your Information

Information You May Provide Us

The types of Personal Information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with Grand Cru Games and the requirements of applicable law. We endeavor to collect information only relevant for lawful purposes of Processing.

Information We May Obtain Through Your Use of Our Products

Through your use of our Products, we may receive the following information about you:

When you use our mobile applications, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data.

In addition to the above, we may need to verify your eligibility and identity in order for you to use some aspects of the Products. For purposes of verification, we may also collect the following personal information from you (for compliance reasons, provision of this information, when requested is a mandatory condition of using certain aspects of the Products):

We may collect information about you at various times, including when:

Information We May Collect from Third Parties

In addition, if you play our games or access any of our other Products on connected third party applications or connect our Products to any third party applications, including social networks, we may receive certain information about you from the provider of the third party application. The information we receive depends on the Grand Cru Games game you're playing, the third party application, your privacy settings and, if applicable, your friends' privacy settings on that third party application. If you access our Products from a third-party application or connect our Products to a third-party application, you should also read that third-party application's terms of service or privacy policy. If you are unclear about what information a third party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

Grand Cru Games may collect information about you from third-party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided us and to enhance our ability to provide you with information about our business, products and services. Grand Cru Games' agreements with these third-party sources typically limit how the Company may use this supplemental information.

How We Use Your Information

We acquire, hold, use and Process Personal Information you provide for a variety of business purposes including to:

Legal Bases for Use of Your Information

The legal bases for using your information as set out in this Privacy Policy are as follows:

Anonymous and Aggregated Information

Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Sites. Anonymized or aggregated information is not Personal Information, and Grand Cru Games may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

The Information We Share With Third Parties

Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. Grand Cru Games requires our service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Grand Cru Games retained them.

We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Grand Cru Games policies or contracts; (v) to collect amounts owed to Grand Cru Games; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; (vii) to prevent or stop activity we consider to be illegal, fraudulent or unethical or to address security or technical issues or (viii) in the good faith belief that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes - e.g., to detect unauthorized activity. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, Grand Cru Games will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy.

We may also provide your Personal Information to third parties to:

Information Shared with Your Consent

We may share or disclose your information at your direction. This includes sharing or disclosing your information that you post or share through our Products, information in your interaction with friends and other players of our games and information with other services such as social or other media or networking services when you have chosen to allow our Products to interact with those services.

Information Shared with Our Service Providers

We may engage third-party service providers to work with us to perform certain services in connection with our providing the Products to you, including hosting services, customer service, marketing services, data analysis, payment processing and order fulfillment, and to help us understand, develop, provide and improve the Products that we offer. These third-party service providers may have access to your Personal Information based on our instructions only for the purpose of performing services on our behalf, and are obligated not to disclose or use your Personal Information for any other purpose.

Information Shared with Our Partners

In connection with the development and provision of our Products and in connection with the provision of games of our partners we may partner with third-party developers, publishers and/or licensors, and other business partners to assist us in providing you with our Products for which you provided your information to us. We only share such information with our partners pursuant to an agreement by which our partner is under obligation not to disclose or use such information for any other purpose. If you wish to no longer have your Personal Information used by our partners, you may contact us at and we will facilitate your request to the partner, understanding, however, that if such information is not shared with our partner, it may affect your ability to use or access portions of our Products.

Information Shared with Third Parties

We may share or disclose your non-private, de-identified, aggregated or otherwise non-personal information with third parties, including third-party publishers, advertisers and ad networks, and businesses with which we partner.

Information Shared with our Related Entities and Affiliates

We may share information with our affiliated companies that are under common control or ownership with Grand Cru Games.

Information Disclosed in Connection with Business Transactions

Information that we collect from our users, including Personal Information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third-party acquirer in connection with the transaction. This Privacy Policy will apply to your information as transferred to the third-party acquirer.

International Transfer of Personal Information

All Personal Information sent or collected by Grand Cru Games may be stored anywhere in the world, including but not limited to, in the United States, on the cloud, our servers, the servers of our affiliates or the servers of our service providers. By providing information to Grand Cru Games, you consent to the storage of your Personal Information in these locations, which may have privacy protections less stringent than your jurisdiction.

As set out in this Privacy Policy, Grand Cru Games may share Personal Information with our service providers, consultants and affiliates to provide you with a product or service that you have requested or for our and our affiliates' internal business purposes. If you are located outside the United States and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and process it there, and you consent to such transfer and processing in the United States.

Social Media and Interest-Based Advertising

We urge you to exercise care and caution when providing information about yourself (e.g., your in-game character name, your user profile, your communications to other users of our Products in forums, message boards or elsewhere in our Products) that may be publically viewable through our Products to others. We recommend that you not publicly disclose any Personal Information. For example, we recommend that you not use your real name or other information that may be used to personally identify you or contact you as part of your in-game character name or your public posts. Grand Cru Games is not responsible for the activities of other users, our partners or other third parties with whom you choose to provide your Personal Information or otherwise interact and/or the manner in which such information is used by others.

All Internet Users - Cookies, Pixel Tags, Web Beacons and Aggregate Information

The technical information and usage statistics may be collected through data collection tools, such as cookies, pixel tags, web beacons and log data when you use our Products. We and/or service providers acting on our behalf, such as Google Analytics and/or our third-party advertisers, use "cookies," which are small text files that websites place on your computing device as you browse the Web, or other similar technologies. We may use both session cookies (that last until you close your browser) and persistent cookies (that last until you or your browser delete them). Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you do not accept cookies, you may not be able to access all portions or features of our Products. Some third-party developers, publishers and other businesses with which we partner (including third-party advertisers) may also place their own cookies on your browser. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user's hard drive. Web beacons are small files that allow us to measure the actions of visitors to our Products. We also use log data that we obtain automatically through our servers.

We may use this information that we obtain through cookies, web beacons, log data and similar data collection tools to identify that you have logged in to our Products, help us better understand how you interact with our Products, personalize and improve your Grand Cru Games experience, develop, provide, customize and improve our Products, evaluate the effectiveness and popularity of our Products, track playing habits, help us to determine the effectiveness of marketing and advertising campaigns (including informing us whether you received and opened our email), monitor, analyze and understand trends, and communicate with you about products or services offered by Grand Cru Games and our partners.

We may analyze (and may engage third parties to analyze) this information as we work to improve your Grand Cru Games experience, develop, provide, customize and improve our Products, offer you targeted ad-selection and delivery in order to personalize your user experience by increasing the likelihood that advertisements for products and services you see will appeal to you, a practice known as behavioral advertising, and undertake web analytics (i.e., to analyze traffic and other end user activity to improve your experience). We may send push notifications to your mobile device to provide Service updates and other relevant messages. You can manage push notifications from the "options" or "settings" page within the mobile application or through your mobile device's settings page for the mobile application. We may use cookies to monitor aggregate usage and web traffic routing for our Products. We may use a person's IP address to fight spam, malware and identity theft. We also may use the IP address to generate aggregate, non-identifying information about how our Products are being used.

We may keep track of how you interact with links across our Products, including our email notifications, third-party products and services, and other applications. We may use information about links to develop, provide and improve our Products, show you more relevant advertising, communicate with you about products or services offered by Grand Cru Games and our partners, personalize your Grand Cru Games experience and be able to share aggregate click statistics such as how many times a particular link was clicked on.

Unless you explicitly opt-in to permit the use and sharing of your Personal Information regarding the geographic location of your computing device, your location data will only be collected and used anonymously in a form that does not personally identify you. Please note that some location-based services may require your Personal Information for the feature to work as intended.

Third-party service providers, advertisers, such as companies delivering advertisements in our Products, developers and publishers may also use cookies or other technologies, and the practices of such third parties are subject to their own privacy policies. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link, the Digital Advertising Alliance's Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

By using our Products, you consent to the use of cookies, web beacons, log data and similar data collection tools by us and our service providers and partners in accordance with this Privacy Policy.

Your Personal Information Rights

Automated Processing and Profiling

You may request at any time that Grand Cru Games provide confirmation of any Processing, including profiling and its consequences. You have the right to object to profiling at any time; the Processing must cease unless Grand Cru Games has a legal basis that overrides your interests, rights and freedoms.

Opt Out

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

Where you have consented to Grand Cru Games' Processing of your Personal Information or Sensitive Personal Information ("Sensitive Data"), you may withdraw that consent at any time and opt out. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.

Prior to disclosing Sensitive Data to a third-party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, Grand Cru Games will endeavor to obtain your explicit consent (opt-in). Where obtaining your consent for the Processing of Personal Information is otherwise required by law or contract, Grand Cru Games will comply with the law or contract.

"Do Not Track"

When using Grand Cru Games' online services, Grand Cru Games may collect personally identifiable information ("PII") about individual users' online activities over time and across different websites or online services operated by Grand Cru Games. To use Grand Cru Games' online services, individual users are connected to their specific accounts and, therefore, Grand Cru Games does not respond to Do Not Track ("DNT") signals. Grand Cru Games shares advertising identifiers with third-party advertising partners and may allow third-party advertising partners displaying advertisements on Grand Cru Games' websites and other online platforms to collect PII about individual users' online activities over time and across different websites or online services.

Rights of Access, Rectification, Erasure and Restriction

Individuals in the European Economic Area and many other jurisdictions have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. Individuals in the European Economic Area may seek confirmation regarding whether Grand Cru Games is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete that information where it is.

Where otherwise permitted by applicable law, you may use any of the methods set out in this Privacy Policy to (i) request confirmation of Processing; (ii) seek access to; (iii) receive (port), including to another controller; (iv) restrict or object to Processing; (v) seek rectification; or (vi) request erasure of Personal Information held about you by Grand Cru Games. Such requests will be processed in line with local laws, including without undue delay and in accordance with any required time frames.

Although Grand Cru Games makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which Grand Cru Games is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question or where it is commercially proprietary. If Grand Cru Games determines that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made within any required time frames (approximately one month), a contact point for any further inquiries and any other legally required information. To protect your privacy, Grand Cru Games will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Grand Cru Games is the controller of personal data collected under this privacy policy (unless we indicate otherwise).

The Security of Your Information

We take reasonable administrative, physical and electronic measures to protect your Personal Information. Unfortunately, however, no security system can be 100% secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Accordingly, we cannot guarantee the absolute security of any information

Links to Other Sites

Our Products may contain links to other websites, and may provide access to products, services and applications owned or provided by third parties not affiliated with or controlled by Grand Cru Games. Any information that you provide on or to a third-party website, product, service or application is provided directly to the owner of that website, product, service or application and is subject to that party's privacy policy. We recommend that you carefully review the privacy policies of the websites, products, services and applications that you access. You agree that Grand Cru Games is not responsible for, nor will Grand Cru Games be liable to you or any third-party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you choose to provide to them.

Outbound Communications

An "Unsubscribe" button will be provided at the top or bottom of marketing-related email communications sent by Grand Cru Games so that you can opt-out. Alternatively, you may unsubscribe at any time by emailing us at However, we will continue to send transaction-related emails regarding Products or services you have requested.


Grand Cru Games will retain Personal Information for as long as you use our Products or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or based upon such other criteria required to comply with contracts and applicable laws.

California Consumers Privacy Rights

The California Consumer Privacy Act ("CCPA") and other California privacy laws provide California residents specific rights in connection with our collection, use, storage, disclosure and processing of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information").

Collection, Use, and Disclosure

The "Information We May Obtain Through Your Use of Our Products" section describes that categories of data we may collect from you, which include, for example account and registration information, name and contact information, alias, demographic and statistical information, financial and transactional information, personal identifiers customer service information, communications with other users, research, survey, or sweepstakes information, information about others, browser and device information and identifiers, connection and usage data, geolocation information, sensory information (such as telemetry and video recordings of gameplay), and questions, comments, or other information you post or share directly with us or within our Products.

The "How We Collect Your Information" section explains the sources from which we collect information about you, including, for example, you, service providers, other users, third party applications, analytics providers, cookies and tracking technologies, survey partners, related entities and affiliates, developer partners, your interaction with us in our social media channels, and marketing partners.

The "How We Use Your Information" section explains how and why we use your information. You can also see the "Legal Bases for Use of Your Information" section for further information on why we collect your information. Generally speaking, we use your information to provide you with the products and services, communicate with you, personalize your experience, secure our services and users, detect and prevent fraud, defend our legal rights, and comply with the law.

The section on "The Information We Share with Third Parties" explains how and with whom we share or disclose your information. We may share information with our related entities and affiliates, service providers, third parties for legal purposes (such as to comply with legal process, enforce our contracts and rights, respond to claims, and protect the rights, property, and safety of Grand Cru Games, our users, and the public), third parties in connection with a corporate transaction, product and marketing partners, and others with your consent.

Please also see our "Social Media and Interest-Based Advertising" and "All Internet Users – Cookies, Pixel Tags, Web Beacons and Aggregate Information" for information on our use of tracking technologies and opt-out choices.

Your Rights and Choices

CCPA Rights Disclosure

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the services to you. We also will take reasonable steps to verify your identity before responding to a request. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please:

California residents may opt out of the "sale" of their personal information. California law broadly defines "sale" in a way that may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on our Products or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you. Depending on what Products you use, we may provide the following categories of personal information to third parties for these purposes: demographic and statistical information, user-generated content, device information and identifiers, connection and usage data, and geolocation.

If you would like to opt out of Grand Cru Games' use of your information for such purposes that are considered a "sale" under California law, you may do so as outlined on the following page: Do Not Sell My Personal Information Right to Opt Out. You can also submit a sale opt-out request by emailing us at Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

Other California Disclosures

The California Civil Code permits customers of our Products who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident and have provided Grand Cru Games with Personal Information within the last year, you may make such a request by contacting us at

If you are under 18 and resident in California, you may request and obtain removal of content or information posted by you on our Products as a registered user of our Products. You may request removal by contacting us at with (i) the email address or user name associated with your registration and (ii) a description sufficient to identify and locate each item of content and/or information posted on our Products by you as a registered user of our Products that you wish removed. Please note that as permitted or required by applicable law, removal does not ensure complete or comprehensive removal of the content or information posted on our Products by you as a registered user. Within 30 calendar days of receiving such a request, we will provide a list of the categories of Personal Information disclosed to third parties for such third parties' direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the email address above.

Nevada Users Privacy Rights

Nevada law provides its residents to opt out of the current and future "sale" of their "personally identifiable information" for monetary consideration to a person for that person to license or sell such information to additional persons. "Personally identifiable information" under Nevada law includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not currently engage in such activity. Nevertheless, if you are a Nevada resident who has purchased or leased goods or services from us you may submit a request by emailing us at Please note we will take reasonable steps to verify your identity and the authenticity of the request. If you move out of Nevada after opting out and update your location, your request to opt out may be voided.

Our Policy Toward Children

Our Products are not intended for or directed to children under the age of 13, or 16 with respect to EU citizens, unless an EEA member state shall otherwise specify, and we do not knowingly collect personal information (as defined by the United States Children's Online Privacy Protection Act) from children under 13 without legally-valid parental consent. Children under 13 or the age of consent in the applicable jurisdiction, should not use or attempt to use our Products, and if you are under 13, or the age of consent in the applicable jurisdiction, please do not attempt to use our Products or send any information about yourself to us. If you become aware that your child has provided us with personal information without your consent, please contact us at to request that such information be removed from our records. If we learn that we have collected personal information of a child under 13 (or 16 with respect to EU citizens, unless an EEA member state shall otherwise specify), we will take reasonable measures to delete such information from our records.


Please contact us at if you have any questions or comments about our Privacy Policy.

Grand Cru Games LLC
PO Box 26209
San Francisco, CA 94126


"Agent" means any Third Party that processes Personal Information pursuant to the instructions of, and solely for, Grand Cru Games or to which Grand Cru Games discloses Personal Information for use on its behalf.

"Data Subject" is an identified or identifiable natural person including you or any user of Grand Cru Games' Products.

"Employee" refers to any current, temporary, permanent, prospective or former employee, director, contractor, consultant, worker or retiree of Grand Cru Games or its subsidiaries worldwide.

"Personal Information" is any information relating to an identified or identifiable natural person ("Data Subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Process" or "Processing" means any operation or set of operations which is performed upon Personal Information or sets of Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Sensitive Personal Information" or "Sensitive Data" is a subset of Personal Information, which due to its nature has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information consists of (a) all government-issued identification numbers (including US Social Security numbers, Canadian Social Insurance numbers, driver's license numbers and passport numbers); (b) Individual financial account numbers (bank account numbers, credit card numbers, and other information if that information would permit access to an Data Subject's financial account); (c) Data Subject medical/health records (e.g., fitness for duty information); (d) Personal Information obtained from a US individual reporting agency and subject to the Fair Credit Reporting Act; and (e) Personal Information regarding EU-residents that is classified as "Special Categories of Data" under EU law, which consists of the following data elements: (1) race, (2) ethnicity, (3) religion or political beliefs, (4) trade union membership, (5) health information or biometric data, (6) sexual orientation or information about the Data Subject's sex life, and (7) information about crimes or alleged crimes committed by the Data Subjects.

"Third party," "Third-Party" "third-party" or "Third Parties" is/are any natural or legal person(s), public authority, agency or body other than the Data Subject, Grand Cru Games or Grand Cru Games' agents.