Welcome to Reckless Company and Via Consulting SLU.

We create mobile applications (“apps”) and real-world mobile augmented reality experiences and games, and operate a real-world augmented reality platform ("Platform").
To make this possible, we need to get data about you. Protecting your privacy is really important to us. We will only use your data when we have a legal basis to do so. This Privacy Policy will help you understand what data we collect, how we use it and what choices are available to you when you play any of our games, use our websites, purchase our merchandise or participate in live promotions and events (the "Services").

Please note that in addition to the general information below, the "Game Specific Information" section at the end of this Privacy Policy contains specific information about how some of our Services use your data.

We also invite you to read the Terms of Service, which set forth the agreement between you and Reckless Company.

1. Who decides how your data is used?

Reckless Company, as the data controller, decides how your personal data is used. If you have any questions or want to make any comments about this policy, you can do so:

* By sending us an e-mail to info@recklesscompany.com

2. What data we collect about you and how we use it

This Privacy Policy governs our use of any data that can or could be used to identify you (the "Personal Data"). It does not cover data that cannot be used to identify you (the "Anonymous Data").

We need to collect and use certain Personal Data in order to provide the Services to you and to fulfill our promises in the Terms of Service:

* When you register for our Services, you voluntarily provide us with Personal Information, for example, when you open an account. We collect and use such data to authenticate your identity when you open an account and use the Services, to ensure that you are able and eligible to receive the Services, and to ensure that you receive the correct version of the Services. Such data includes the username in the game you choose to use in our Services and the internal IDs we assign to your account.

* Depending on the particular Service you register for, we may offer to support other external single sign-on services provided by third parties and collect additional Personal Data through them. For details, please see the section entitled "Specific Gaming Related Information" at the end of this Privacy Policy.
Some third-party providers may notify you that they will make certain additional information available to us, such as your public profile, when you use their single sign-on services. We do not collect such data from these third parties.

* We collect and use your device location data as you use our Services (and, if you choose to activate background location on our Services, also when you are not directly interacting with the Services), including how you move around and events that occur during game play. Our Services include location-based games, the main feature of which is that they provide you with a gaming experience linked to your location in the real world. Consequently, we need to know where you are to make these games work for you and plan the location of in-game resources. We identify your location through different technologies, including GPS, the WiFi points through which you access the Service and the triangulation of your mobile device/phone with phone repeaters.

* We also collect and use information about your in-game actions and achievements, as well as certain information about your mobile device (including device identifiers, operating system, model, configuration and settings, and information about any third-party applications or software installed on your device), to operate the Services for you, and to customize your game time and user experience.

* The above data is also used to show you sponsored in-game locations that are near you as part of the gaming experience.

* Additionally, we use such data to provide you with technical support and our customer service.

* You also provide us with Personal Information when you make a purchase through us, subscribe to our publications, register for an event, enter a contest, promotion, sweepstakes or survey, or communicate with us. Depending on which of these Services you use, Personal Information may include your name, mailing address, telephone number, country of residence, date of birth (if necessary to verify your eligibility) and e-mail address. We use this data to provide you with these Services and to provide you with our customer service.

In addition, we have a legitimate interest, on which we rely, in using your Personal Data for the following purposes:

* We use your IP address, browser type, operating system, the web page you are visiting before accessing our Services, the pages of our Services that you have visited or the features you have used and the time you have spent visiting such pages or using such features, the links located in our Services on which you click, your device and advertising identifiers, as well as the actions you take during game play, your in-game settings and user preferences and the purchases you make within the app, to understand who is using our Services and how.

* We use your contact information, i.e. your email address, to communicate with you to provide technical support and our customer service.

* We use your internal account identifier to attribute to your account user content (such as local points of interest) that you choose to submit to Reckless Company via the Services.

* We use your email address and device details to share news and updates with you, either within the games themselves or via email. You may unsubscribe from these communications at any time from the settings on your device or the app itself.

* Analyze your actions and achievements in the game to show you rewards, promotions or other offers related to our Services that fit your own user experience. You may opt out of this and other processing of your personal data by following the steps described in Section 7 below.

* Offer you social features within our games so that you can interact and play with other players, including storing your communications with those players, finding your friends and letting them find you, and sharing your gaming experience and achievements with your friends.

* To provide AR experiences. To do this, Reckless Company needs to obtain geospatial AR data locally from your device's camera. This geospatial data is then analyzed by Reckless Company's servers to allow you and other players to view and interact with the same virtual objects at the same time in a shared physical space. Please see our Help Center for more information on AR experiences and privacy.

* Offer you new or additional features for our Services

* Organize and conduct live events featuring our games or related to them. Please note that when you participate in live events, your in-game actions and achievements, your in-game username and avatar, your team and other components of your game profile will be visible to other event participants and the general public (e.g., on the leaderboards displayed at the event and online).

* We use your progress and achievements in the game, as well as certain information about your mobile device (including device identifiers, device operating system, model, configuration, settings and information about third-party applications or software installed on your device) to take action against fraud and cheating against prohibited conduct under our Terms of Service to ensure that we provide a fair gaming experience for all players.

* Communicate information that is necessary from a legal or regulatory standpoint and acknowledge, exercise or defend a right in legal proceedings.

We will only use your Personal Data for the following purposes if we have obtained your consent:

* If you choose to activate background activity tracking on our Services we will collect your Personal Data while you are using the Services, and also in the background when you do not have the Services open on your device. This includes the location of your device and your physical activity data (such as step counts, calories burned, and distance traveled). We use background activity tracking to provide you with certain functionality in the Services, such as in-game items and rewards that are linked to your level of physical activity and alerts on surrounding gaming events. You can change your mind and turn off background activity tracking at any time, either in your device settings or in the internal settings of the application.
With your permission, we use your device's health app (Apple HealthKit if you use an Apple device, or Google Fit if you use an Android device) to collect your physical activity data: we read and/or write your physical activity data into your device's health app to make the activity tracking work in the background and to ensure that your walking activity while playing our games is recognized in your device's health app. We do not use data collected through Apple Health Kit or Google Fit for advertising or marketing purposes. Our Services cannot read or write on your device's health application without your consent. You may change your mind and disable access to any physical activity data at any time in the Apple Health or Google Fit application settings on your device.

* If you choose to give permission for User Friends on Facebook available in some of our games, we will import for your linked Facebook account the list of your friends who also play the game and who have also allowed access to User Friends on Facebook. If you grant such permission, your Facebook profile picture and your Facebook account name will be visible to your friends in the game. You can change your mind and unbind other players at any time from the application's Friends settings. You can also revoke Facebook permissions for our games directly from your Facebook account settings.

* If you choose to add information about live events or in Reckless Company's own games to your mobile calendar, we will, with your permission, access your device's calendar and write down these events. We do not access or collect any other information from your calendar. You can change your mind and disable access to the calendar at any time in your device settings.

* If you choose to assist Reckless Company in its efforts to develop new augmented reality (AR) mapping technology, you have the option, in participating games, to choose to film public spaces around points of interest and send us your video recordings, along with the geospatial information of the associated device. We do not collect audio on these recordings. We will anonymize this information through various means, including blurring, and use it to build a 3D understanding of real-world locations, with the goal of offering new types of AR experiences to our users. You can change your mind at any time by disabling this feature in your configuration within the app.

* If you choose to connect your game account to an authorized external device, we will request Bluetooth permission from your mobile device to connect you to the external device and enable the associated game features. You can change your mind at any time by disabling our Bluetooth access in your device settings or disconnecting the external device from the game.

* Send you marketing communications by email or by notifications within the app. You can unsubscribe to these communications at any time from your device settings or from the app itself.

We will also rely on your consent to use cookies or similar technologies. Please see our Cookie Policy for more information about how we use such cookies or technologies. To the extent that cookies collect Personal Data, we will only process such Personal Data with your express consent, on an anonymous basis or under a pseudonym.

Although you can disable the use of cookies from your browser settings, Reckless Company does not currently respond to "non-tracking" signals on the HTTP header from your browser or mobile application due to the lack of industry standards on how to interpret such signals.

3. Who we share data with

We will only share Personal Data relating to you or that we have collected from you in the manner described below:

Data shared with our service providers. We engage external service providers to assist us in administering and delivering the Services. As part of their duties, they will carry out the processing of your Personal Information on our behalf. These external service providers will have access to your Personal Information solely for the purpose of providing services on our behalf in accordance with this Privacy Policy, and we will ensure that each of them is contractually bound not to disclose or use your Personal Information for any other purpose. The service providers we work with help us to:

* offer, manage and maintain our Services through third party computer platforms and tools;

* moderate content and analyze failures;

* develop e-mail and text message campaigns;

* carry out game and marketing analysis;

* manage live events, contests, sweepstakes and promotions, including registering players, managing accreditation and attendance, verifying eligibility and awarding prizes

* manage payment assignments;

* provide technical support and customer service; and

* process payment for tickets to live events or other purchases.

Other third party service providers may also collect information directly from you (e.g., a payment processor may request your financial and billing information) as a Third Party Service, according to their own privacy policy. Such third party service providers will not share your financial information, such as credit card number, with Reckless Company, but may share with us certain limited information regarding your purchase, such as your zip code.

Data shared with other players. When you use the Services and, in particular, when you play our games, use the social features in those games (including features shared between different games) or participate in live events, we will share certain Personal Information with other players. This Personal Information includes your in-game profile (which includes your username, avatar, online status and computer), your in-game actions and achievements, the real-world location of in-game resources with which you have interacted while playing the games, and your public in-game messages. In addition, certain games contain links to third-party sharing features on your device that you may use to share Personal Information with others outside of the Services; Reckless Company does not control and is not responsible for the practices of these third-party sharing features.

Publicly Shared Information: When you use the Services, and in particular when you play our games, use competitive features or participate in our forums, the following information about you may be shared on publicly accessible web pages and therefore become publicly available: your user name, your in-game profile, your achievements and your public messages.

Data shared with third parties. We share Anonymous Data with third parties for industry and market analysis. We may share Personal Information with our publishing partners for their direct product marketing purposes, but only with their express permission. We do not share Personal Information with any other third party for direct marketing purposes.

Data communicated for our protection and the protection of third parties. We collaborate with state administration officials, law enforcement agencies or private entities to comply and enforce the law. We only share data about you with government officials, law enforcement agencies or private parties when we believe it is reasonably necessary or appropriate to do so: (a) to respond to lawsuits or service of process (including subpoenas or warrants); (b) to protect our property and rights and our safety or the property and rights and safety of others or the public; and (c) to investigate and prosecute any activity we believe to be unlawful or ethically objectionable or for which legal action may be taken.

Information communicated in the context of corporate transactions. The data we collect from our users, including their Personal Data, is a business asset. In the event that a third party acquires Reckless Company within the framework of a transaction, for example, a merger, acquisition or sale of assets or if our assets are acquired by a third party in the event that we cease our activity or declare ourselves bankrupt, part or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer within the framework of the transaction.

4. How the transfer of your Personal Data takes place

Reckless Company offers its services worldwide. It is highly likely that your Personal Data will be transferred to a country other than the one in which you reside, including the United States, for storage for the purposes described in this Privacy Policy. The data protection laws of these countries may not coincide with the legislation in force in your country of residence.

If we transfer your Personal Data from the EEA to other countries, including the United States, we will ensure that the level of protection received by your Personal Data is similar to that existing within the EEA, by ensuring that at least one of the following safeguards is in place:

* That the country to which your Personal Data are transferred is a country which is considered by the European Commission to offer an adequate and comparable level of protection of Personal Data to that which exists within the EEA.

* That we use specific contracts approved by the European Commission that provide Personal Data with the same protection that they enjoy in the EEA when we hire service providers.

* That, when we engage service providers in the USA, they adhere to the EU-US Privacy Shield, which requires them to protect Personal Data relating to you with the same diligence as in the EEA.

5. How we ensure the security of your Personal Data

We have taken appropriate security measures to prevent accidental loss of your Personal Data, unauthorized access to or use of your Personal Data, and the alteration or improper disclosure of your Personal Data. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a professional reason to know that information. Such parties will only carry out the processing of your Personal Data in accordance with our instructions and are subject to a duty of confidentiality. We have established procedures to act upon any suspected breach of Personal Data and will bring to your attention and that of the competent regulatory authority any breach if we are legally obliged to do so.

6. How long we will keep your Personal Data

We will retain your Personal Information for as long as necessary to provide you with the Services and to fulfill the purposes described in this Privacy Policy. The same will apply to any third party with whom we share your information and provide services on our behalf.

When we no longer need to use or retain your Personal Information to fulfill our legal or regulatory obligations, we will either delete it from our systems or anonymize it so that it can no longer be associated with you. When we delete Personal Data, we will take commercially reasonable and technically feasible steps to make such Personal Data unrecoverable and non-reproducible.

7. Your rights and options

You have certain rights in relation to your Personal Data. To exercise these rights, please contact us by sending an email to info@recklesscompany.com.

You can:

* Request access to the Personal Data we keep about you by sending an e-mail to info@recklesscompany.com

* Delete or rectify your Personal Data. The easiest way to update your account data is through the settings in the app itself. You can also request assistance from customer service through our support website.

* Request that we stop processing your Personal Information, including for promotional and direct marketing purposes, such as rewards, promotions and other personalized offers, by sending an email to info@recklesscompany.com. However, please note that on occasion we will need to use your Personal Data in order to provide you with the Services).

* Request that we transfer your Personal Data to another organization (to the extent technically feasible).

* File a complaint with a regulatory authority. In this regard, we would appreciate it if you would first contact us so that we can convey your concerns directly to us and give us the opportunity to resolve them. However, if you live in the EEA and believe that we have not complied with applicable data protection legislation, you may file a complaint with the relevant regulator at your local supervisory authority.

The law provides for exceptions to these rights in certain circumstances. If you are unable to exercise any of these rights because of such an exception, we will explain why.

We offer you a number of choices regarding the collection, use and disclosure of your Personal Data and we will respect the choices you make. Please note that if you choose not to provide us with the Personal Information we request, you may not be able to access all features of the Services.

Our goal is to provide you with the information or result you have requested within 30 days.

8. Children

Unless otherwise stated for a particular Service, children are not allowed to use the Services. Child" means a person (a) under the age of 13 (for residents outside the EEA, except for the Republic of Korea); (b) under the age of 16 or such age as is necessary to consent to the processing of personal data in the country where he or she resides (for residents of the EEA); or (c) under the age of 14 (for residents of the Republic of Korea).

For Services that allow the Child to participate, the parent or legal guardian ("Parent") must provide verified consent. Where Parental consent is required, Reckless Company recommends that Parents monitor the Child's online activity and use of the Service.

The verification and consent process for Children is performed by one of several third party providers ("Verification Provider"). The Parent must register with the Verification Provider before a Child can use the Services. The Verification Provider will ask the Parent to verify his/her identity and consent to the creation of an Account for the Child. Upon receipt of verification and consent from the Parent, the Verification Provider will allow the Parent to create a Child Account. Parental consent applies only to the Service for which it has been given.

If a Parent wishes to revoke the consent previously given for a Child's access to and use of the Services, the Parent must follow the Account cancellation instructions, which can be found at the respective Help Centers.

Purchases made through the Services are restricted to Account holders who are either (a) of age to contract in their country of residence; or (b) if a minor, have a Parent's consent to use the Service. Parents may refer to their device's settings for the App to restrict purchases that the Child may make through the App, and should also monitor the Child's Account activity, including purchases of Virtual Money or Virtual Goods.

TO THE EXTENT PERMITTED BY APPLICABLE LAW, RECKLESS COMPANY DISCLAIMS ALL LIABILITY IN CONNECTION WITH ANY ACTIVITY BY A CHILD WITH OR WITHOUT A PARENT'S PERMISSION. IF YOU ARE A PARENT AND GIVE YOUR PERMISSION FOR YOUR CHILD TO SUBSCRIBE TO ONE OR MORE OF THE SERVICES, YOU AGREE TO THE TERMS REGARDING YOUR CHILD'S USE OF THE SERVICES.

If you have any questions about our privacy practices with respect to Children, you may contact us at info@recklesscompany.com.

9. Modification of this Privacy Policy

The Personal Data we collect is subject to the Privacy Policy in force at the time of collection. We may amend this Privacy Policy from time to time. You will be reasonably notified of any significant changes.

10. Third parties

By using our Services, you will be able to access links to websites and services owned or operated by third parties (each, a "Third Party Service"). The data you provide on a Third Party Service or collected by a Third Party Service will be provided directly to the owner or operator of the Third Party Service and will be subject to that owner's or operator's privacy policy. We are not responsible for the content or the privacy or security practices and policies of any Third Party Service. To protect your data, we recommend that you carefully read the privacy policies of all Third Party Services that you access.