Last updated 10/15/2022

Jubal Online Games is headquartered in Washington State.

This privacy policy describes the different ways we may collect, use, and share information on, through, or in connection with any of our game services.

When we refer to "Jubal" (or any similar terms like "we" or "us") in this privacy policy, we mean the Jubal Online Games entity that controls and is responsible for your information. You can also find details about the Privacy Officer for personal information we collect through our services below.

Jubal Services

We use the term "Jubal Services" to describe any Jubal products or services that directly link to this privacy policy. These notably include the game ORG.

Please read this entire privacy policy. You should also carefully review any other agreements that apply to the Jubal Services you use, and confirm you understand and agree to them, before using those products or services.

Personal Information

For the purposes of this policy, "personal information" means information about an identifiable individual or that could be used to identify an individual. Examples of personal information include, for example, an individual's name, home address, telephone number, e-mail address, social insurance number, sex, income and family status. Applicable Privacy Laws contain more robust definitions (including exclusions), but for the purposes of this policy we use this to make it clear.

Non-Personal Information

Applicable Privacy Laws may allow for some exceptions to what is considered personal information. "Non-Personal Information" is any type of information other than personal information, and is excluded from this policy.

For example, non-personal information would include business information, or information that enables an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. Non-personal information also includes information that is anonymous or not about an identifiable individual, such statistical information about web browsing (such as the domains used to access the Website, or the type and version of devices, browsers or operating systems being used to access the Service), or aggregate information that anonymizes the underlying data (like the number of visitors, what pages users visit, average time spent on the Website or on various parts of the Service).

We will collect, use or disclose non-personal information in accordance with our ordinary business practices, but always in accordance with any applicable laws. This policy, however, only covers our collection, use and disclosure of personal information.

Information About Minors

This site is intended solely for users who are 13 years of age or older. We do not knowingly collect personal information about any person under the age of 13, and no such person, nor any parent or guardian as it relates to such person, should submit their personal information to us for any reason. Please do not submit personal information about minors to us, whether through the website, the game service or otherwise.

Global Privacy Acts

Jubal Online Games is based in the United States, but we may process the information we collect in connection with your use of the Jubal Services in places outside the region where you reside.

Data Transfers

When you use the Jubal Services, your information may be transferred to or stored in the United States or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. If permissible under local law, you are authorizing Jubal to process your information in any of the locations where we operate (including the United States) by using the Jubal Services.

California Residents

The California Consumer Privacy Act or "CCPA" provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to: (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (2) request deletion of your personal information; (3) opt out of sale of your personal information (if any); and (4) not be discriminated against for exercising these rights.

You or your authorized agent may make these requests by contacting us below. Note that we may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA.

We collect the following categories of personal information, as described in the CCPA:

  • Identifiers (such as email addresses)
  • Demographic information (e.g., ages)
  • Commercial information (including entitlements or purchase history)
  • Internet or electronic network activity (e.g., gameplay or website usage details)
  • Audio, electronic, visual, or similar information (e.g., voice chat)
  • Geolocation information (such as may be derived from your IP address or included in your billing information)
  • Other personal information as defined under California law (e.g., your credit or debit card information)
  • Inferences drawn from any of these categories

Jubal does not sell the personal information we collect. We do, however, disclose personal information as described in this policy. We reserve the right to disclosed personal information to the following categories of recipients:

  • Other users (for example, if you use chat or social features on the Jubal Services)
  • Service providers
  • Operating systems and platforms
  • Government entities or other third parties in response to a legal request

European Economic Area (EEA), United Kingdom, and Switzerland Residents

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed.

Data Subject Rights

You may have the right to access, correct, or delete personal data we have collected about you through the Jubal Services. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. Where you have provided your consent to our data processing, you have the right to withdraw consent.

You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.

Please contact us as described below to learn more about reaching out to Jubal with any relevant concerns you may have. You can find more details about your local Data Protection Authority as follows:

  • EEA: https://edpb.europa.eu/about-edpb/board/members_en
  • UK: https://ico.org.uk/global/contact-us/
  • Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Basis for Processing

The legal bases we rely on to process your personal data depend on the Jubal Services you use and how you interact with them. They primarily include:

  • Contractual Necessity: we process personal data to perform the Epic Services you requested under our Terms of Service or other similar contractual agreements with you. For example, we process personal data to set up and maintain your account; process your purchases; authenticate users; provide user-experience features (like saving your preferences); monitor and analyze the Jubal Services; detect and prevent fraud, cheating, or other similar misuse; facilitate features like cross-progression that allow you to play a game on one platform and continue your progress on another, which may require us to share your information with third-party partners; and contact you about your account, transactions, or other updates. We also rely on performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to our applicable terms or policies.
  • Legitimate Interests: we process personal data as needed for Jubal's business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you’d reasonably expect, such as to: communicate with you, respond to your requests, or provide you with updates and information; better understand our users and their preferences; personalize your experience, save your preferences, authenticate our users, and provide similar user experience features; develop, deliver, and improve the Epic Services and other offerings (some of which may be offered in partnership with other parties); manage and customize advertisements or promotional offers; secure and protect the Jubal Services; prevent fraud and illegal activity; and support internal purposes such as auditing and data analysis.
  • Legal Obligations: we process personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes.
  • Consent: we process personal data when you provide us with your consent to do so. You aren’t required to provide consent if you do not want your personal data to be processed for the requested purposes, and you may withdraw your consent at any time.


Because the specific personal data we process and our reasons for doing so often vary depending on how you use the Jubal Services, how long we retain it can also vary. We generally store personal data for as long as we reasonably need it for the purposes described in this policy (like complying with our legal obligations, managing internal records, enforcing our terms, and resolving disputes), unless a long retention period is required or permitted by law.

The main criteria we consider in determining specific retention periods often include minimum requirements under applicable law, relevant industry standards, the types of data in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (like defending ourselves against legal claims), and whether the data is required to prevent fraud or similar abuse of the Jubal Services (including to enforce prohibitions against cheating and other unauthorized behavior). For example, if you create a Jubal account, we will generally store the personal data associated with your Jubal account for as long as needed to maintain your account, provide the Jubal Services you requested, enforce any terms that apply and govern your use of the Jubal Services, and maintain appropriate records to reflect how we deliver the Jubal Services to you.

Privacy Officer

You can direct any questions or concerns regarding our compliance with this policy to our Privacy Officer by contacting us at geoff.tuffli@jubal.com If you are not satisfied with our Privacy Officer's response to a question or concern you may be able to make a complaint under Applicable Privacy Laws. Our Privacy Officer can provide you with the contact information to make such a complaint.


Information we collect from you

We may collect the following personal information from you:

  • Contact information such as name and email address
  • Unique identifiers such as user name, account number and password
  • Your performance within our games and applications, such as high scores
  • Preferences information such as request history and marketing preferences
  • any information that you voluntarily enter, including personal information, into any postings, comments, reviews or forums

Information we automatically collect

We may also automatically gather information about your computer or through your platform such as your IP address, browser type, referring/exit pages, operating system, as well as which aspects of our performance metric indicators available with our technology or Services you prefer using. Some of this may be personal information, but in some cases it is non-personal information. Specific examples follow:

  • IP, etc. - When using our website, we may collect the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access our website, the Internet address of the website from which you linked directly to our website, the operating system you are using, the sections of our website you visit, the Website pages read and images viewed, and the content you download from the website. This information is used for website and system administration purposes, and to improve the website.
  • Cookies - We may use "cookies", a technology that installs a small amount of information on a user's computer to permit the website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies is used to recognize you as a previous user of the website, to offer personalized content and information for your use, to track your activity at the website, to respond to your needs, and to otherwise facilitate your website experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the website and your ability to access certain features of the website or engage in transactions through the website.
  • Tracking Information - We may use web beacons or single-pixel gif tags to compile tracking information reports regarding website user demographics, website traffic patterns, website purchases and other aggregated website statistics, and may be used in our emails to determine which emails and links have been used by recipients. We may then provide these reports to advertisers and others. None of the tracking information in these reports can be connected to the identities or other personal information of individual users. For our own research purposes we may link tracking information with personal information voluntarily provided by website users. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this policy.
  • Geolocation Information - When you use the Jubal Service through a mobile device, we may track or collect your geolocation information on a real time basis only. We may also use this real-time geolocation information to address support, technical, or business issues that may arise in the course of your use of the Service. If you do not consent to the tracking of your geolocation, you may still be able to use some features of the Jubal Service, but it is intended to be used with geolocation information.


We may use your personal information, in combination with your non-personal information, for a variety of business purposes, for example to:

  • Send you requested information
  • Send you new product or service information
  • Respond to customer service requests
  • Send you a newsletter
  • Send you marketing communications
  • Respond to your questions and concerns
  • Manage accounts you have with us
  • For other purposes as described in this policy.


We will collect, use, or disclose your personal information where we are required or permitted to collect, use or disclose your personal information by Applicable Privacy Laws. This policy is designed to give you knowledge of how we collect, use and disclose it. Also, when you choose to provide us with your personal information, you consent to the use of your personal information as identified in this policy and as may be further identified at the time of collection.

Express Consent

Sometimes you will be asked to give your express consent to our collection, use or disclosure of personal information - for example, by being asked to check a box to indicate your consent to receive marketing communications in compliance with various anti-spam laws.

Implied Consent

Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you - for example, when you provide us with your email address through a form or email seeking information, you provide us with implied consent to use that email address in order to respond to your request.

Withdrawing Your Consent

You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure or your personal information. We will accommodate your request subject to legal and contractual restrictions. The most common way of indicating this withdrawal of consent is (i) by changing your privacy preferences to the extent such functionality is made available through the Service, or (ii) deleting your account with the Jubal Service and stopping use of the Jubal Service. In other situations, you may be able to opt out of the use of your personal information. For example, if you have opted in or subscribed to one of our mailing lists, we will always provide you the opportunity to opt out or unsubscribe. For example, if you receive emails from us, we will provide a link in the email which you can use to unsubscribe from that mailing list, or you may contact us at geoff.tuffli@jubal.com

You may also choose not to provide us with your personal information. However, if you make this choice, or if you withdraw your consent, we may not be able to provide you with some or all of the Jubal Service, or information that you have requested.


If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us and in accordance with this policy and such policy under which that information was collected.

For example, if you access the Jubal Service through a platform like Valve Steam, Microsoft's Xbox Live, or Sony's PlayStation Network, those platforms may collect and provide information to us information that may be considered personal information under Applicable Privacy Laws, which we will always treat in accordance with those third party's policies and our own set out herein; we will only use that information to provide you the applicable services (e.g., offering achievements, providing leaderboards and high scores).


We will share your personal information with third parties only in the ways that are described in this policy. We will not sell your personal information to third parties, however the use of our Service necessarily requires some sharing or disclosure of your personal information. Some of these activities may result in personal information collected by us being stored or processed in the United States or elsewhere outside of Canada and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the USA PATRIOT Act, the USA FREEDOM Act and other applicable laws of the United States or elsewhere.

Third Party Processors

We may provide your personal information to companies that provide services to help us with the Service such as web hosting providers, payment processors, product shipping providers, fulfilment agencies, or customer service agencies ("Third Party Processors"). These Third Party Processors are authorized to use your personal information only as necessary to provide these services to us, and in a manner consistent with this policy. We have selected Third Party Processors who will only use your information in compliance with this policy, but they may have their own specific policies regarding the collection, use and disclosure of personal information that will apply. We will use commercially reasonable efforts to identify such Third Party Processors when we are collecting your personal information, as well as providing links to the relevant privacy policies that may apply.

Further Disclosures

We may also disclose your personal information (i) as required by law such as to comply with a subpoena, or similar legal process, (ii) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, or (iii) to any other third party with your prior consent to do so.

Third Party Links

The Jubal Service may contain links to other websites or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting another website or Internet resource. We have no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites to learn how they collect and use your personal information.


The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect personal information, and insist that our service providers do the same. We insist that our personnel, and those of our providers, only access and use personal information in order to properly perform those duties, and even then only to the strict extent necessary to perform them.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so you should always exercise caution when disclosing sensitive information over the Internet.


Applicable Privacy Laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:

  • Identification of personal information under our custody or control
  • Information about how personal information under our control may be or has been used by us
  • The names of any individuals and organizations to which the individual's personal information has been disclosed

We will respond to requests within the time allowed by Applicable Privacy Laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.

In certain exceptional circumstances, we may not be able to provide access to certain personal information it holds about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.


We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous. We also comply with Applicable Privacy Laws regarding the removal of your information.


We may update this policy to reflect changes to our information practices. If we make any material changes we will either (a) notify you by email (sent to the e-mail address specified in your account), or (b) provide a notice on the Website or otherwise through the Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Any change to this Privacy Policy will become effective on the date so indicated, and will apply to information collected from the date of the posting of the revised privacy policy and to existing information held by us. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this privacy policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this policy.