Privacy Policy

Effective April 28, 2020

Scopely, Inc. has acquired certain businesses, including those providing the services described below. This policy has been updated to reflect that transaction and recent updates to California law.

Table of Contents:

  1. SCOPE AND APPLICATION: What and who this Policy covers
  2. COLLECTION OF INFORMATION: The sources of and methods by which we, our service providers and our advertisers collect information from and about you, including information about your interaction with the Services
  3. USE AND DISCLOSURE: How we use the information we collect from and about you, and who we might share it with and why
  4. SECURITY: How we protect your information from loss or misuse
  5. USER ACCESS AND CONTROL: How you can access and control the information we maintain about you
  6. OTHER IMPORTANT INFORMATION: Other things you should know about this Policy and how we handle your information
  7. CALIFORNIA RESIDENTS: What we are doing to meet the obligations of the California Consumer Privacy Act (“CCPA”) and other important information for California residents
  8. CONTACT US: How to contact us about this Policy


This Privacy Policy describes our practices related to information collected in connection with MARVEL Strike Force, Avatar: Pandora Rising, and their related websites, mobile sites, applications (“apps”), and widgets (collectively, the “Services”). By using the Services, you agree to the terms and conditions of this Privacy Policy. For purposes of this Privacy Policy, “Scopely” (or “we,” “us,” or “our”) refers to Scopely, Inc. and its parents, subsidiaries, representatives, affiliates, officers, and directors.

As set forth in our Terms of Use, the Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 13 years of age.

This Privacy Policy applies to all users, including both those who use the Services without being registered with or subscribing to a Service and those who have registered with or subscribed to a Service. This Privacy Policy applies to our collection and use of your personal information (i.e., information that identifies, whether directly or indirectly, a specific person, such as full name or email address). When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.


We and our service providers may collect the following information from and about you:

  • Registration Information is the information you submit to register for a Service, for example, to create an account, post comments, receive notifications, newsletters and other communications, participate in a survey conducted by us or on our behalf by a third party service provider, or enter a contest or sweepstakes. Registration Information may include, for example, name, username, email address, phone number, gender, ZIP or postal code, birthday, location, device information, information about your use of the Services, and any other information you choose to provide.
  • Public Information and Posts consist of comments or content that you post to the Services and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines. BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS ON THE SERVICES. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.
  • Information from Social Media. If you access or log-in to a Service through a social media service or connect a Service to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access the Services through social media services or when you connect a Service to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.
  • Activity Information. When you access and interact with the Services, we and our service providers may collect certain information about those visits. For example, in order to permit your connection to the Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device. When you use the Services to participate in our mobile games, we may collect scores, rankings, transaction information, and other information regarding your gameplay. Additionally, when you communicate with us, we may retain information regarding these communications.
  • Cookies and Other Tracking Technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology) are comprised of small bits of data. The Services send this data to your browser when you first request a web page and then store the data on your computer or other device so the website or app can access information when you make subsequent requests for pages from that service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, the video and other content you have viewed, search queries you have run and advertisements you have seen.

    Third parties that support the Services by serving advertisements or providing services, such as allowing you to share content (e.g. Facebook) or tracking aggregate Services usage statistics (e.g. Google Analytics), may also use these technologies to collect similar information when you use the Services (such as websites or emails) or third-party services. These third parties may also use these technologies, along with activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. We do not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled “To deliver relevant advertisements,” below.

    Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information. Users can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website, see Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Services.

  • Information from Other Sources . We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services, commercially available sources and information from our Company Affiliates or business partners.
  • Do Not Track Signals . At this time we do not respond to browser 'Do Not Track' signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted.


We use and disclose the information we collect from and about you to provide the Services and features to you, including: (1) to measure and improve those Services and features and to develop new products and services; (2) to improve your experience with both online and off-line Services by delivering content you will find relevant and interesting, including advertising and marketing messages; (3) to allow you to comment on content, and participate in online games, contests, other promotions, or rewards programs; and (4) to provide you with customer support and to respond to inquiries. In order to provide you with content and advertising that is more interesting and relevant to you, we may use the information we receive from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

We use the information we collect from and about you for these additional purposes:

  • To allow service providers to assist us in providing and managing the Services. The information we collect from and about you may be made available to certain third party service providers, such as contractors, analytics and other measurement companies, agents or sponsors, who help us analyze and understand your use of the Services, provide customer support, advertising and marketing, and manage and/or provide the Services.
  • To allow social sharing functionality. If you log in with a social media service, or connect a social media service account with the Services, we may share your user name, picture, and likes, as well as your activities and comments with other Services users and with your friends on your social media service. We may also share the same information with the social media service provider. By logging in with or connecting your Services account with a social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your Services account and do not participate in social sharing on the Services.
  • To provide co-branded services and features. We may offer co-branded services or features, such as contests, sweepstakes or other promotions together with a third party (“Co-Branded Services”). These Co-Branded Services may be hosted on the Services or on the third party’s service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party’s use of your information will be governed by the third party’s privacy policy.
  • To deliver relevant advertisements. We and our service providers may use the information we collect from and about you to deliver relevant ads to you when you use the Services (on any of your devices) or another service. As noted above, third-party advertising networks and advertisers may use cookies (which keep track of information such as web pages you visit and your interaction with our advertising and other communications) and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and information the different devices you use and your activity on such devices, to assist them in delivering advertising that is more relevant to your interests. The information may also be used to deliver more relevant advertising to consumers across marketing channels, including email. To find out more about third-party advertising networks and similar entities that use these technologies, see . If you would like to opt-out of such ad networks’ and services’ advertising practices on the particular device on which you are accessing this policy, go to if you are in the United States or if you are in Canada, to opt-out in desktop and mobile web browsers. You may download the AppChoices app at if you are in the United States or if you are in Canada, to opt-out in mobile apps. To opt-out of Google Analytics specifically, go to

    If you are using an iOS device, you may opt out of tracking for advertising purposes by clicking on Settings -> Privacy -> Advertising -> Limit Ad Tracking. If you are using an Android device, you may opt out of tracking for advertising purposes by going to Settings -> Google Settings -> Ads -> Enable “Opt out of Ads Personalization.” Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.

    We may use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please contact our Privacy Officer using the contact information set out, below.

  • To contact you. We may periodically send promotional materials or notifications related to the Services. If you want to stop receiving promotional materials via email, follow the unsubscribe instructions at the bottom of each email. There are certain service notification emails that you may not opt-out of, such as notifications of changes to the Services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
  • To share with business partners. We may share your information with business partners to permit them to send you marketing communications consistent with your choices.
  • To protect the rights of Scopely and others. There may be instances when we may use or disclose your information, including situations where we have a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Scopely or its employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.
  • To complete a merger or sale of assets. If we sell all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), we may transfer your information to the party or parties involved in the transaction as part of that transaction.


We use commercially reasonable administrative, technical, personnel and physical measures to safeguard information in its possession against loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information. To increase the effectiveness of the security features incorporated through the Services, please ensure that any mobile application utilizing the Services is kept updated.


If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information in our custody or control, you may contact us as outlined in Section 8. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress, or delete. We may request certain additional personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. We will try to comply with your request as soon as reasonably practicable and in accordance with applicable law. Note that there are some reasons we may not be able to fully address a deletion request, such as, for example, if we need to retain your data to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation.

We do not share your personal information with unaffiliated third parties for those parties’ direct marketing use unless a user elects that we do so.

Deletion Rights of Minors. If you are under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to us as outlined in Section 8. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.


Updates to Privacy Policy. We may modify this Privacy Policy. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services.

Location of Data. The Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information (which may include information collected through the use of cookies and other technologies, as described above) processed in the United States or in any other country in which we have facilities or in which we engage service providers. United States and other countries’ data protection and other relevant laws may not be the same as those in your jurisdiction. This includes the use of cookies and other tracking technologies as described above. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information. For more information regarding the location of the data, please contact us using the information provided at Section 8 below.

Linked Services. The Services may be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. We are not responsible for the privacy practices of unaffiliated companies, and once you leave the Services or click an advertisement you should check the applicable privacy policy of the other service.

In addition, we are not responsible for the privacy or data security practices of other organizations, such as Facebook, Tumblr, Twitter, Apple, Google, Microsoft, Amazon or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Services.

Collection of Personal Financial Information by a Payment Service . In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service's privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service's use of information collected through any Payment Service.

Data Retention. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise.


The California Consumer Privacy Act or "CCPA" (California Civil Code Section 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

In the preceding 12 months, we have collected the following categories of personal information about certain California residents: identifiers (such as name, contact information and device identifiers); limited demographic information (such as gender if included in registration information you choose to submit); commercial information (such as items purchased in a game); internet or other network activity information (such as information regarding your interactions with the Services); geolocation data; audio, electronic, visual, or similar information (such as profile picture and any content you have permitted a social media service to share with us); and inferences. For examples of the precise data points we collect and the categories of sources of such collection, please see “Collection of Information” above. We collect personal information for the business and commercial purposes described in “Use and Disclosure” above. We share this information with the categories of third parties described in the “Use and Disclosure” section above.

California residents may also take advantage of the following rights:

  • You may request, up to two times each year, that we disclose to you (1) the categories and specific pieces of personal information that we have collected about you, (2) the categories of sources from which your personal information is collected, (3) the business or commercial purpose for collecting your personal information, (4) the categories of third parties with whom we disclosed your personal information for a business or commercial purpose, (5) the business or commercial purpose for disclosing your personal information; (6) any categories of personal information that we sold about you; and (7) the business or commercial purpose for selling your personal information, if applicable.
  • To take advantage of any of these rights, please contact us as outlined in Section 8. We value your privacy and will not discriminate in response to your exercise of your privacy rights.
  • California Civil Code Section 1798.120 may permit you to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA). This Privacy Policy describes the limited circumstances in which we may share your information with third parties outside Scopely. Our Privacy Policy also provides you with certain controls and choices regarding our collection, use, and sharing of your information, which may include:


If you have questions about this Privacy Policy, please contact us at:


Mail: Scopely, Inc., Attn: Legal, 3530 Hayden Avenue, Culver City, CA 90232