Alpha Privacy Policy
Effective: March 18, 2024
Welcome to the Alpha App (herein “App”). The App is owned and operated by Astra Games Ltd. This
Privacy Policy will provide you, the User, with information about Alpha’s (herein “we”, “us”, “our”, or
“Alpha”) App processing activities with respect to your Personal Information collected through your use
of the App and/or our website ("Website”). This policy applies to our App Users that have downloaded
the App and to website users browsing or visiting our Website.
The App and Website are available to users all around the world. Accordingly, throughout the
document, we try to harmonize our approach and the language of the privacy policy as much as
possible. However, sometimes we refer to specific laws that require further disclosures. For example,
whenever you see throughout the policy the annotation “The GDPR angle”, it means that the purpose of
such section is to satisfy the transparency requirements of the General Data Protection Regulation (the
“GDPR”), and therefore it applies only to personal data (as defined by the GDPR) associated with devices
who we deem to be located in the European Economic Area, United Kingdom, or Switzerland. If you are
a resident of California Colorado, Connecticut, Utah or Virginia, please see “State Privacy Rights” section
of this privacy policy for information related to privacy laws in these states.
We collect information as described in this privacy policy for Alpha own purposes as a data controller
under data protection law where relevant.
Personal Information We Collect and its Sources
By downloading and using the App and/or browsing or visiting our Website, we collect Personal
Information from you in either of two ways:
• Directly from you when you provide it to us.
• Indirectly when you use the App.
Personal Information that you actively provide, may include:
● Account Information: The Personal Information you submit to create an Alpha account may
include your name, age or date of birth, telephone number, mobile number, email address,
gender, username, Password(s) that Users create to access parts of the Service or profile
picture.
● Financial Information: Details of transactions you carry out through the App and information
necessary for the fulfillment of your orders. When Users provide payment (e.g. credit card
information, billing address, etc.) information to make a purchase, that information is sent to
payment processors who assist Alpha. Alpha's payment systems are not designed to store credit
card numbers.
● Verification information: As part of the Astra Coins redemption process, you may be required to
submit Personal Information for verification purposes. This information may include your
government issued identification card (e.g., license or passport), and a “video selfie”. In some
jurisdictions, the "video selfie" may be considered biometric data. The verification process is
facilitated through a third-party face verification technology (FaceTec, Inc.) and your Verification
Information is not shared during this process. The “video selfie” data is encrypted on your
device in an unrecoverable manner before being sent to our servers for processing and is not
stored after the verification process is complete. You do not have to provide us your verification
information. However, this may mean that you will not be able to redeem Astra Coins.
● Your Communications with Us: The Personal Information you submit to contact us (e.g.
customer support, submit a request) may include your name, email address, account ID, OS
(operating system) and any messages or other information you wish to share with us.
By downloading and using the App, Alpha, and the third party companies that provide Alpha with
advertising, marketing, and analytics services, may passively and automatically collect the below
Personal Information from you:
● Usage Information. We collect information about your activity through our App. Information
about your usage may include how you use the app, its content, length of use, transactions that
you make, etc.
● Device Information. The App may also collect device information such as the device
identification, operating system, hardware and software versions, platform, screen size, and
CPU/graphics characteristics.
● Location Information. When you use our App we may collect information about your general
location by inferring it from the device’s IP address. IP addresses can be used to learn about the
general location (e.g. city, state and country) of the User’s point of access to the App.
When you access or use the Website, we may use industry-wide technologies such as “cookies” (or
similar technologies), which store certain information on your computer and which will allow us to
enable automatic activation of certain features, and make your service experience much more
convenient and effortless. It is easy to prohibit certain cookies. You can do so by editing your
preferences through the Site’s cookie settings link. In addition, most browsers will allow you to erase
cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a
cookie is stored. However, if you block or erase cookies your online experience may be limited.
Purpose of Collecting Personal Information (How we use your Data)
We use the Personal Information we collect through your download and use of the App to
provide, administer, operate and improve the App and its related Services (together,
“Services”). Specifically, we may use your Personal Information for the below purposes.
● Providing the functionality of the Services and fulfilling your requests, including to:
o To create, administer and troubleshoot accounts, Services we provide;
o To provide technical support and respond to inquiries;
o To prevent fraud, enforce the relevant terms of service or licenses, and protect
Users.
● Providing you with our newsletter and/or other marketing materials and facilitating
social sharing
o To send you marketing related emails, with information about our services, new
products and other news about our company;
o To facilitate social sharing functionality that you choose to use.
● Accomplishing our business purposes.
o To perform analytics and research aimed at improving the accuracy,
effectiveness, usability, or popularity of the App;
o For providing you with the offerwall functionality, which allows you to choose
from a page of various rewarded offers ("Offerwall");
o For data analysis and testing, for example, to improve the efficiency of our App;
o For App maintenance;
o For reporting and hosting of data;
o For audits, to verify that our internal processes function as intended and are
compliant with legal, regulatory or contractual requirements;
o For fraud and security purposes, for example, monitoring to detect and prevent
cyberattacks or attempts to commit identity theft;
o For uniquely verifying your identity;
o For the prevention of criminal activity or harm to users of our Services;
o For developing new products and services;
o For enhancing, improving, or modifying our current website(s), products and
services and/or assisting our developers with this activity;
o For identifying usage trends, for example, understanding which parts of our
website(s) and Services are of most interest to users;
o For determining the effectiveness of our promotional campaigns, so that we can
adapt our campaigns to the needs and interests of our users or our publisher’s
and other advertising customer’s users; and
o For operating and expanding our business activities, for example, understanding
which parts of our Services are of most interest to our users or assisting our
developers with this activity within their business so we can focus our and their
energies and resources on meeting our users’ interests;
● Analysis of Personal Information for business reporting and providing personalized
services.
o To analyze or predict our users’ preferences in order to prepare aggregated
trend reports on how our App is used, so we can improve our website(s) and
Services.
o To better understand you, so that we can personalize our interactions with you
and provide you with information and/or offers tailored to your interests.
o To better understand your preferences so that we can deliver content via our
website(s) and Services that we believe will be relevant and interesting to you.
● Aggregating and/or anonymizing Personal Information.
o We may aggregate and/or anonymize Personal Information so that it will no
longer be considered Personal Information. We do so to generate other data for
our use, which we may use and disclose for any purpose.
The GDPR Angle:
● Under the GDPR, we rely on the following legal basis for the processing of personal
data:
o We process personal data for providing services to players of our App for the
performance of our contract with them.
o We process personal data for the purposes of preventing fraud or potentially
illegal activities, protecting our rights and property, serving advertising (except
for personalized advertising), uniquely verifying the user's identity (except for a
selfie authentication), conducting marketing campaigns (except for audience lists
based campaigns), improving and optimizing the App, providing information and
promotional offers to players of our App, administering rewards and conducting
research, based on our legitimate interests.
o We, or our advertising partners, may process personal data for the purpose of
serving personalized advertising, game usage analytics, or conducting marketing
campaigns based on audience lists and creating such audience lists, if we, or our
advertising partners, obtained that user’s consent.
o We may process personal data for the purposes of uniquely verifying the user's
identity through a selfie authentication if we obtained that user's consent.
o We may also process your personal data for compliance with applicable legal
obligations.
How we might share the information we collect or receive
● To our affiliates for the purposes described in this Privacy Policy.
● To our third-party service providers, to facilitate services they provide to us.
○ These can include providers of services such as website hosting, data analysis,
payment processing, order fulfillment, information technology and related
infrastructure provision, customer service, email delivery, marketing, mailing,
surveys, auditing, and other services.
○ Specifically, we use the following service providers:
■ Tapjoy, Inc. (https://dev.tapjoy.com/en/legal/Privacy-Policy) – For
providing you with the Offerwall functionality.
■ Tilia LLC (https://www.tilia.io/legal/privacy-policy) – For supporting our
in-app currency, transactions, and withdrawals, which includes
conducting Know Your Client ("KYC") compliance checks.
■ Appsflyer (https://www.appsflyer.com/legal/services-privacy-policy/) –
For supporting our marketing activities of the App.
■ Tremendous (https://www.tremendous.com/privacy) – For enabling in-
app gift cards and other redemption options.
■ Firebase (https://firebase.google.com/support/privacy) – For the purpose
of receiving analytics services and supporting our marketing activities of
the App.
■ Playfab (https://privacy.microsoft.com/en-us/privacystatement) – For
supporting our in-app currency, transactions, and app features.
● To third parties, to permit them to send you marketing communications, consistent
with your choices.
○ Ads: Depending on the version of the App you are using, we may utilize the data
collected from the App to place personalized ads in the App and elsewhere. This
usage will permit other parties, such as publishers and attribution companies, to
learn about the devices that received, viewed or interacted with ads.
○ Third-party products and services: we may permit advertisers and their agents to
store information on or read information from your device so that they can
optimize their advertising campaigns, including to frequency cap and deliver
targeted ads.
● To comply with applicable law and regulations.
○ This can include laws outside your country of residence.
● To cooperate with public and government authorities.
○ To respond to a request or to provide information we believe is important
○ These can include authorities outside your country of residence.
● To cooperate with law enforcement.
○ For example, when we respond to law enforcement requests and orders or
provide information we believe is important.
● For other legal reasons.
○ To enforce our terms and conditions or licenses; and
○ To protect our rights, privacy, safety or property, and/or that of our affiliates,
you or others.
● In connection with a sale or business transaction.
○ We have a legitimate interest in disclosing or transferring your Personal
Information to a third party in the event of any reorganization, merger, sale,
joint venture, assignment, transfer or other disposition of all or any portion of
our business, assets or stock (including in connection with any bankruptcy or
similar proceedings) Such third parties may include, for example, an acquiring
entity and its advisors.
How to Control Information:
Collection of device data – Updated version of Android enable you to control how apps can
collect the Advertising ID. Please follow the instructions set forth at:
https://support.google.com/ads/answer/1660762 (under Mobile Controls). Please note that if
you use more than one device, you need to opt-out separately in each device.
The GDPR Angle:
o Withdraw consent – You have the right to withdraw the consent you provided to
us from within our App, or by following the instructions above on how to control
collection of device data. Please note that the consent you provide during the
verification process cannot be withdrawn, as the data associated with the "video
selfie" is processed only once, and is not stored after the completion of the
verification process.
o Data subject rights – Please note that you have the right to request from us
access to and rectification or erasure of your personal data we process as
controllers, or to restrict or to object to processing of your personal data in
accordance with the provisions of the GDPR. To submit a request for exercising
your rights, please send an email with your request to the following address:
support@astra-app.com. Please note that we will process your request subject
to verification of your identity.
o Complaint to supervisory authority– You also have the right to file a complaint
with the relevant supervisory authority (e.g., of your country or domicile) where
Alpha has not addressed your concerns.
Accessing/ Updating/ Deleting Your Information
Subject to applicable law, you may have a number of rights regarding the Processing of your
Personal Data. Please send any requests or questions to support@astra-app.com.
Retention
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for
which it was obtained and consistent with applicable law. The criteria used to determine our
retention periods include:
● The length of time we have an ongoing relationship with you and provide the Services to
you (for example, for as long as you have an account with us or keep using the Services);
● Whether there is a legal obligation to which we are subject (for example, certain laws
require us to keep records of your transactions for a certain period of time before we
can delete them); or
● Whether retention is advisable in light of our legal position (such as in regard to
applicable statutes of limitations, litigation or regulatory investigations).
Transfers out of Country of Collection
● Your Personal Information may be stored and processed in any country where we have
facilities or in which we engage service providers, and by using the Services you
understand that your information will be transferred to countries outside of your
country of residence, including the EU, and UK, which may have data protection rules
that are different from those of your country. In certain circumstances, courts, law
enforcement agencies, regulatory agencies or security authorities in those other
countries may be entitled to access your Personal Information.
The GDPR Angle:
○ Alpha is based in Israel, which is considered by the European Commission to be
offering an adequate level of protection for the Personal Information of EU
Member State Residents.
○ We will transfer personal data to third parties located outside of the European
Economic Area, the United Kingdom, or Switzerland based on standard
contractual clauses. You can ask us for a copy of these clauses by contacting us
through the below contact details.
Our Policies Concerning Children
If you are under the age of 18, you must not use the App and/or the Website.
If you or your parent or guardian have questions about this policy or how we use your personal
information, you can contact us at support@astra-app.com.
Links to Other Sites
● As a reminder, this statement only describes Alpha’s practices with regards to the App
and the Website. If you are being directed, redirected, or otherwise offered to
download a third party app, or browse to a third party website, you should carefully
review the privacy policy of such app, or website.
Changes to This Privacy Statement
● We reserve the right to change our practices and this statement at any time. We may
send an email or provide notice within some or all of our offerings when this statement
changes. We encourage you to check this page regularly so that you know what our
current practices are.
Contact Us
Astra Games Ltd.
121 Menachem Begin Rd., Tel Aviv, Israel
If you have any questions about this Privacy Policy, please contact us at support@astra-
app.com
Because email communications are not always secure, please do not include credit card or
other sensitive information in your emails to us.
State Privacy Rights
Additional Information for Residents of California, Colorado, Connecticut, Utah
and Virginia
Collection, Disclosure, Sharing, and Sale of Personal Information
California Colorado, Connecticut, Utah and Virginia residents have certain rights under state
privacy laws with respect to personal data we collect. If you are a resident of such states, this
section of the privacy policy contains disclosures required by law and explains rights that may
be available to you.
The following chart details which categories of Personal Information we collect and process, as
well as which categories of Personal Information we disclose to third parties for our operational
business purposes, including within the 12 months preceding the date this Privacy Policy was
last updated. The chart also details the categories of Personal Information that we “sell” or
“share” for purposes of cross-context behavioral or targeted advertising, including within the
preceding 12 months.
Categories of Personal Information
Disclosed to
Which Categories
of Third Parties
for Operational
Business Purposes
Shared with
Which
Categories of
Third Parties for
Cross-Context
Behavioral or
Targeted
Advertising
Sold to
Which
Categories
of Third
Parties
Identifiers, such as name, signature,
contact information, online identifiers,
and government-issued ID numbers
affiliates; service
providers; ad
networks;
marketing
partners; legal
authorities
ad networks;
marketing
partners;
ad
networks;
marketing
partners
Personal information as defined in the
California customer records law, such
as name, contact information,
payment card number, financial
information, medical information,
insurance information, education
information, employment information,
and government-issued ID numbers
affiliates; service
providers; legal
authorities
None
None
Characteristics of protected
classifications under California or
federal law, such as sex, age, race,
disability, and marital status
None
None
None
Commercial Information, such as
transaction information and purchase
history
affiliates; service
providers;
marketing
partners; legal
authorities
None
None
Biometric information, such as scans of
hand and face geometry
None
None
None
Internet or network activity
information, such as browsing history
and interactions with our Services
affiliates; service
providers; ad
networks;
marketing
partners; legal
authorities
ad networks;
marketing
partners
ad
networks;
marketing
partners
Geolocation Data, such as approximate
location derived from IP address
affiliates; service
providers; ad
networks;
marketing
partners; legal
authorities
ad networks;
marketing
partners
ad
networks;
marketing
partners
Audio/Video Data. Audio, electronic,
visual, and similar information, such as
call and video recordings
N/A
N/A
N/A
Education Information subject to the
federal Family Educational Rights and
Privacy Act such as student records,
directory information
N/A
N/A
N/A
Employment Information. Professional
or employment-related information,
such as work history and prior
employer
None
None
None
Inferences drawn from any of the
Personal Information listed above to
create a profile or summary about, for
example, an individual’s preferences or
characteristics
None
None
None
Sensitive Personal Information.
● Personal Information that reveals
an individual’s social security,
driver’s license, state
identification card, or passport
number; account log-in, financial
account, debit card, or credit card
number in combination with any
required security or access code,
password, or credentials allowing
access to an account; precise
geolocation; racial or ethnic
origin, religious or philosophical
beliefs, citizenship, immigration
status, or union membership; the
contents of mail, email, and text
messages unless Alpha is the
intended recipient of the
communication; genetic data;
● The processing of biometric
information for the purpose of
uniquely identifying an individual;
● Personal Information collected
and analyzed concerning an
individual’s health;
● Personal Information collected
and analyzed concerning an
affiliates; service
providers; legal
authorities
None
None
individual’s sex life or sexual
orientation;
● Personal Information collected
from a known child.
Individual Requests
Subject to applicable law, you may make the following requests:
1. You may request to know whether we process your Personal Information, and to access
such Personal Information.
• If you are a California resident, you may request that we disclose to you the
following information covering the 12 months preceding your request:
o The categories of Personal Information we collected about you and the
categories of sources from which we collected such Personal Information;
o The business or commercial purpose for collecting or sharing Personal
Information about you;
o The categories of Personal Information about you that we shared (as
defined under the applicable privacy law) and the categories of third
parties to whom we shared such Personal Information; and
o The categories of Personal Information about you that we otherwise
disclosed, and the categories of third parties to whom we disclosed such
Personal Information (if applicable).
2. You may request to correct inaccuracies in your Personal Information;
3. You may request to have your Personal Information deleted;
4. You may request to receive a copy of your Personal Information, including specific
pieces of Personal Information, including, where applicable, to obtain a copy of the
Personal Information you provided to us in a portable format;
5. You may request to opt out of the “sale” of your Personal Information; and
6. You may request to opt out of targeted advertising, including the “sharing” of your
Personal Information for purposes of cross-context behavioral advertising.
Please note that Alpha has placed a California Notice of Rights on its website to explain how
California residents may exercise their privacy rights under the California Consumer Privacy Act.
This notice is incorporated into this policy.
We will not unlawfully discriminate against you for exercising your rights under applicable
privacy law.
To make a privacy request, please contact us at support@astra-app.com or Astra Games Ltd.,
121 Menachem Begin Rd., Tel Aviv, Israel. We will verify and respond to your request consistent
with applicable law, taking into account the type and sensitivity of the Personal Information
subject to the request. We may need to request additional Personal Information from you,
such as your account information / email address / device type/ device ID where applicable, in
order to verify your identity and protect against fraudulent requests. If you make a request to
delete, we may ask you to confirm your request before we delete your Personal Information.
You can also exercise your right to opt out of sales and sharing of your personal data, including
for targeted advertising purposes, by opening the privacy settings in the App, and toggling on
the Do Not Sell or Share My Personal Information button. We do not knowingly sell or share the
Personal Information of minors under 16 years of age. Appeal Process
If you are a Colorado, Virginia, or Connecticut consumer, and we refuse to take action on your
request, you may appeal our refusal within a reasonable period after you have received notice
of the refusal. You may file an appeal by contacting us support@astra-app.com or Astra Games
Ltd., 121 Menachem Begin Rd., Tel Aviv, Israel.
Authorized Agents
If an agent would like to make a request on your behalf as permitted under applicable law, the
agent may use the submission methods noted in the section entitled “Individual Requests.” As
part of our verification process, we may request that the agent provide, as applicable, proof
concerning his or her status as an authorized agent. In addition, we may require that you verify
your identity as described in the section entitled “Individual Requests” or confirm that you
provided the agent permission to submit the request.
De-Identified Information
Where we maintain or use de-identified information, we will continue to maintain and use the
de-identified information only in a de-identified fashion and will not attempt to re-identify the
information.
Providing Personal Information to third parties for direct marketing purposes: California
residents have the right to request the identity of any third parties to whom the resident’s
Personal Information was provided, if such provision was to enable the third party’s direct
marketing efforts. If you are a California resident and wish to make such a request, please
submit your request to support@astra-app.com. Alternatively, you may opt-out of having your
personal information shared with third parties for their direct marketing purposes, by emailing
us at support@astra-app.com.
