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PRIVACY POLICY – Prior Versions – January 29, 2021

Current Policy Version

Last Updated: January 29, 2021.

This Privacy Policy (“Policy”) explains how Computer Lunch, LLC (referred to as “Computer Lunch”, “we”, “us”, or “our” in this Policy) collects, stores, uses, or otherwise processes the personal data of end users of our Services as defined below (referred to as “you” or “your” in this Policy), and what rights you have if we are processing your personal data. In this Policy, “Services“ refers to our Games, Websites, and any related services or properties we directly control. “Games” refers to mobile, computer, and console games or applications that we own and operate. “Websites” refers to websites and other online properties we control, including www.computerlunch.com and www.celltosingularity.com. We use the term “your data” or “personal data” to refer to data that relates to you as an identified or identifiable individual (such as your name or email address), including non-personal data that can be combined with other data to potentially identify you. We strongly encourage you to read this Policy before accessing or using our Services so that you are aware of how and why we may use data relating to you. In addition to this Policy, we encourage you to carefully review our Terms of Service, which govern your use of our Services.

1. Data Controller

By “data controller”, we mean an entity that determines how and why personal data is processed. With regard to the personal data we process as described in this Policy, we are the data controller. Our company name is Computer Lunch, LLC. Our address is 689 Fort Washington Ave., #4, New York, NY 10040, USA. While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to section 6 of this Policy.

2. Contact Information

In matters related to this Policy, you can reach us by email at privacy@computerlunch.com. You can also reach us by mail at 689 Fort Washington Ave., #4, New York, NY 10040, USA.

3.Why do we process your data and on what basis?

3.1. Basis

When we process or collect your data, we ensure that we have a valid basis for doing so. Below, you can find examples of the different purposes for which we process your data and the bases for those reasons: 

In order to provide well-maintained Services to you, improve your experience as a user, and ensure a fair and safe environment for all users, we may process your data to:

In order to promote our Services and to make sure we reach interested audiences, we may process your data to:

With your consent, we may process your data to:

3.2. Advertising

Advertising is one of the tools that helps fund our Services and enables us to make our Games available free of charge. In some of our Games, we may show our own ads and also ads from third parties. We also advertise our Games outside of our Services on third-party properties such as websites or applications. This section provides more information on how we may use your data for advertising purposes, and how you can control the use of your data for these purposes. Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses or other identifiers. An “Advertising ID” is an alphanumeric string of digits provided by the operating system of your mobile device (e.g. your phone or tablet). It is consistent across applications from different publishers. The Advertising ID is known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices. Advertising IDs are used for interest-based advertising and other advertising related purposes. You can control the extent to which your Advertising ID is used for these purposes. Using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising ID. For example, you can “limit ad tracking” on iOS devices or “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them as you prefer on each of your devices individually. It may take some time for your updated settings to take effect. Please consider that resetting or limiting the use of your Advertising ID will not stop you from seeing ads or necessarily reduce the number of ads you see, but the ads you see may be less relevant to you and will not be served based on your personal data. For more information on mobile privacy settings, you may refer to third-party resources such as: https://www.networkadvertising.org/mobile-choice

When you see ads in our Games, we may share your Advertising ID and IP address with our advertising partners if you have given your consent to the use of your data for personalized ads. Our advertising partners may also collect information directly from our Games through technologies such as software development kits (SDKs). In each case, they may use your data for a number of purposes, including to limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID). For more information, please refer to the privacy policies of our advertising partners listed here. If you do not provide us with consent to use your data for personalized ads, we will not share your personal data (such as Advertising ID) with our advertising partners and will indicate to them that you have not consented to the use of this data for personalized ads.

When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID, have determined that you may be interested in our Services. Ad networks may also use your data to:

In addition, ad networks may provide services where they use Advertising IDs or other identifiers to find users who are likely to be interested in our Services because their past activity or interests are similar to those of others known by the ad network to use our Services. When ad-networks use your Advertising ID in these ways, they do so based on their respective privacy policies or notices.

For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as total views, clicks, or installs generated by an ad. Measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as web beacons inserted into ads. This data is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.

4. What data do we process?

We may process the following data relating to you:

We do not expect or intend to collect or otherwise process any special categories of data relating to you, such as genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offenses or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.

5. Where do we collect your data from?

We may collect data relating to you from the following sources:

Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this Policy, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games, use your device settings to reset or limit the use of your Advertising ID, or withhold consent for customized advertising in your device settings.

6. Whom do we share your data with?

We may share your data with third parties to achieve the purposes described in this Policy. This may include sharing data with the following types of recipients:

7. How long do we keep your data?

We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. We may periodically delete or de-identify inactive accounts or other data in our Games or other Services. After the applicable retention period, we will either delete or de-identify your data or, if neither deletion or de-identification is possible (for example, due to data being stored on a backup server), isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregate data).

8. How do we secure your data?

We have adopted measures to provide your data a level of security appropriate for the degree of risk involved with the data processing activities described in this Policy. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ vary depending on the sensitivity of the data, but typically include, for example, encryption, pseudonymization of identifying data where feasible, controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents.

9. Your Rights

For users located in the European Union (“EU”) and the European Economic Area (“EEA”), if we are processing your data, you have the right to:

Where our processing of your data is based on your consent, you also have the right to withdraw your consent at any time. Please be aware that we may continue processing your data despite your withdrawal of consent, if we also have another lawful basis for doing so. To access your data in our Games or to request its deletion, please contact us at privacy@computerlunch.com. To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message. To exercise any of your rights, you may also contact us at privacy@computerlunch.com. To fulfill requests submitted by email, we may need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you. For example, we may ask you to provide sufficiently detailed information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf. While we will usually not do so, we reserve the right to charge you an appropriate fee for the exercise of your rights where permitted by applicable laws and regulations. If you believe that we have infringed your privacy rights, please contact us so that we can try to resolve the issue. However, if you are an EU resident, you have the right to lodge a complaint with your local supervisory authority.

10. International Transfer

Computer Lunch is a company based in the United States and your data will be transferred to the US for processing. US privacy laws may be very different from those of your country. However, as described in this Policy, Computer Lunch takes steps to protect your data and your privacy rights after international transfer. Computer Lunch’s transfer to the US of the data of EU/EEA residents is permitted by EU law (GDPR) on the basis that it is necessary to perform a contract (providing you with the Services under our Terms of Service) between you and us.

11. Age Limit

Under our Terms of Service, you represent that you are at least 13 years of age. However, we do not know the specific age of individual users of our Services. If you are under 13 years of age, please do not provide your personal data (including your name, address, telephone number, or email address) to us or use the Services to make your personal data available to others. If we discover that we unintentionally hold personal data relating to a user under 13 years of age, we will take appropriate measures to ensure that we process that data according to the requirements of applicable laws and regulations or promptly delete the data from our records. If you have reason to believe we hold personal data relating to a user under 13 years of age, please contact us.

12. Controlling Language

This Policy may be provided in multiple languages as a courtesy, however, the English language version of this Policy will control in the event of any conflict between the meaning of terms in the English version and any version provided in another language.

13. Changes

We may update this Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also inform you of any changes by other means that are appropriate to the significance of the changes.

14. Supplemental Privacy Disclosure for California Residents

If you are a California resident, please be aware that under the California Consumer Privacy Act of 2018, as amended (“CCPA”) establishes specific rights for California residents to control their personal information and requires businesses to provide specific information to California residents regarding how their personal information is collected, used, and shared.

Computer Lunch provides this Disclosure (“Disclosure”) to California residents who use our Services, including our Websites and our Games (referred to as “you” in this Disclosure) to provide you the information required by the CCPA and to inform you of your rights under the CCPA. This Disclosure supplements our Privacy Policy., which provides more comprehensive information on how and why we may process data relating to you. We recommend that you read our Privacy Policy in conjunction with this Disclosure.

In this Disclosure, the terms “Services”, “Games”, and “Websites” have the same definitions provided in our Privacy Policy, above.

1. Your Rights

Under the CCPA, California residents have certain rights to their personal information. If you are a California resident, you may exercise these rights as explained below.

When you submit a request to exercise your rights, we are required to verify that you are the consumer to whose personal information the request relates or a person authorized to act on that consumer’s behalf. If you submit your request using the automated tools provided in our Games, we will usually not need additional information to verify your request. For requests submitted by other means (for example, by email), we may ask you to provide additional information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf.

Right to Know. You have the right to know what personal information about you we collect, from which sources, for which purposes, and with whom we share it. You also have the right to request the specific pieces of personal information we have collected about you. This request can be made free of charge twice in any 12-month period. Moreover, you have the right to know which categories of personal information we have sold or disclosed for a business purpose.

For information on what personal information we collect, from which sources, for which purposes, with whom we share it, and whether we disclose it for business purposes, please refer to section 2 of this Disclosure. In addition, section 3 of this Disclosure describes the extent to which we may “sell” your personal information in the meaning of the CCPA.

You may request a copy of your personal information by contacting us at privacy@computerlunch.com. For more information, please refer to section 9 of our Privacy Policy, above.

Following your deletion request, we may either erase or de-identify your personal information.

Right to Opt-Out. You have the right to direct us to not “sell” your personal information (please see Section 3 of this Disclosure for further details on what this means under the CCPA and the situations in which we might do so). If you decline to give consent or contact us to opt out, we will no longer share your identifiers and other information with our ad partners to make the ads you see more relevant to you. To exercise your right to opt-out, please contact us at privacy@computerlunch.com or decline to give consent to such sharing within a Game when you see a message asking for consent.

Non-Discrimination. You have the right to not be discriminated against for exercising your rights under the CCPA.

2. How We Collect, Use, and Share Your Personal Information

What follows is a summary of how we may collect, use, and share your personal information. the summary is provided in the format we believe to be required by the CCPA. Please review our Privacy Policy, above, for additional information.

We regularly collect the following categories of personal information specified in the CCPA:

Category of personal information Examples Sources
Identifiers In-game alias, IP address, hardware or operating system based identifiers, email address, or identifiers we assign to your account. Directly from you (including automatically when you interact with our Games), our advertising partners (to the extent you interact with our ads outside of our Games), third-party account providers (if you link a third-party account to our Games), or third-party payment service providers (if you make purchases in our Games).
Commercial information Information regarding your virtual items or currency in our Games, including records of purchases you may have made. Directly from you (including automatically when you interact with our Games) and third-party payment service providers (if you make purchases in our Games).
Internet or other electronic network activity information Information on your activity in our Games (for example, your game progress or your interactions with ads in our Games). Directly from you (including automatically when you interact with our Games), our advertising partners (to the extent you interact with our ads outside of our Games).
Geolocation data Your coarse location (for example, country, state, or city), determined based on your IP address. Directly from you (including automatically when you interact with our Games).
Inferences drawn from this information to create a profile about you Your geolocation or preferences used to personalize our Games for you. We make these inferences based on the other categories of information.


We may use this information for the following business purposes specified in the CCPA:

We may share the information with recipients such as our service providers to achieve these business purposes. This means that we may disclose the categories of personal information listed above for a business purpose.

In addition, some features of our Games (for example surveys, or tools used to contact our player support) may allow you to submit information about yourself to us. We may collect any information you choose to submit to us using these features. In addition to the personal information listed in the table above, this may include other categories of personal information specified in the CCPA, including:

We only collect these categories of personal information directly from you, and you may choose not to submit this information to us at your discretion. We may use the personal information you choose to submit for performing our services (for example, to handle your support enquiries) and short-term, transient uses, and we may share the information with recipients such as our service providers to achieve these business purposes. This means that we may disclose these categories of personal information for a business purpose.

3. How We May Sell Your Personal Information

Under the CCPA, a business is required to provide notice to a consumer before the business sells the consumer’s personal information to third parties. the CCPA defines a “sale” as not only exchanges for monetary consideration, but also disclosures of personal information for other valuable consideration.

We do not sell your personal information in exchange for money. However, we may disclose a limited amount of your personal information (i) to our advertising partners to enable them to deliver an ad that is relevant to you or (ii) to our marketing partners to enable them to send you relevant offers when you have opted in to such communication. This includes the following categories of your personal information:

Because this disclosure of information could be deemed a “sale” in the meaning of the CCPA, we either ask for your explicit consent or provide a means for you to direct us to not disclose your personal information to our advertising or marketing partners for the above purposes. To learn how to exercise your right to opt-out, please see “Right to Opt Out,” above.

If we have actual knowledge that you are under 16 years old, we will not sell your personal information without affirmative authorization.