Privacy Policy

Forester Games · Effective 9 August 2026 · Last revised 9 August 2026

THIS PRIVACY POLICY (the "Policy") describes the practices of Forester Consulting Canada Incorporated, a corporation existing under the laws of the Province of Ontario, Canada, having its principal place of business at Georgetown, Ontario, operating in respect of interactive entertainment software under the trade name and division "Forester Games" (the "Company", "we", "us" or "our"), with respect to the collection, use, disclosure, retention and processing of information in connection with the mobile software applications published by the Company from time to time, including without limitation the application known as "Don't Say a Word" and any further applications identified in Section 4 hereof (each, an "Application" and collectively, the "Applications"). BY DOWNLOADING, INSTALLING, ACCESSING OR OTHERWISE USING ANY APPLICATION, THE USER ACKNOWLEDGES THAT THE USER HAS READ, UNDERSTOOD AND AGREES TO BE BOUND BY THE TERMS OF THIS POLICY. IF THE USER DOES NOT AGREE TO THE TERMS OF THIS POLICY, THE USER SHOULD NOT DOWNLOAD, INSTALL, ACCESS OR USE ANY APPLICATION.

1. DEFINITIONS. For the purposes of this Policy, the following terms shall have the meanings ascribed to them below. "Advertising Identifier" means the Identifier for Advertisers (IDFA) made available by the operating system of the User's device, together with any successor, equivalent or substitute device-level identifier. "Applicable Privacy Laws" means, collectively and as applicable, the Personal Information Protection and Electronic Documents Act (Canada), S.C. 2000, c. 5, as amended, Regulation (EU) 2016/679 (the General Data Protection Regulation), the United Kingdom General Data Protection Regulation as incorporated into domestic law by the European Union (Withdrawal) Act 2018, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and any other statute, regulation, rule, order or binding guidance relating to privacy or the protection of personal information that is applicable to the Company in respect of the Applications. "Device" means the mobile computing device upon which an Application is installed. "Personal Information" means information about an identifiable individual, and shall be construed to include "personal data" and "personal information" as those terms are defined under the Applicable Privacy Laws. "Third Party Advertising Provider" means Google LLC and its affiliates, operating through the service commonly known as Google AdMob, and any successor or replacement provider engaged by the Company from time to time. "User" means any natural person who downloads, installs, accesses or uses any Application.

2. CORPORATE IDENTIFICATION. Forester Games is a division of Forester Consulting Canada Incorporated and is not a separate legal entity. All references in this Policy to the Company, and all rights and obligations arising hereunder, are to and of Forester Consulting Canada Incorporated. Contact particulars are set out in Section 13 hereof.

3. SCOPE. This Policy applies to each Application published by the Company under the Forester Games name, and to no other product, service, website or offering of Forester Consulting Canada Incorporated. Where an individual Application collects or processes information in a manner differing from that described herein, such variance is disclosed in Section 4. In the event of a conflict between this Policy and any app-specific disclosure set out in Section 4, the app-specific disclosure shall govern in respect of that Application only.

4. APPLICATIONS COVERED BY THIS POLICY. (a) Don't Say a Word. A word game for iOS. This Application displays advertising supplied by the Third Party Advertising Provider as described in Section 6, and offers optional turn-based multiplayer functionality operated through the Game Center service of Apple Inc. as described in Section 8. This Application does not require account registration and does not transmit information to any server operated or controlled by the Company. (b) Additional Applications. Applications released by the Company subsequent to the effective date of this Policy shall be added to this Section, and the effective date revised accordingly, prior to or contemporaneously with their release.

5. NO ACCOUNT REGISTRATION; NO COMPANY-OPERATED SERVERS; LOCALLY STORED INFORMATION. The Applications do not require, request or permit the creation of a user account, and the Company does not operate, maintain or control any server, database, repository or other facility that receives, stores or processes Personal Information transmitted from any Application. The Company does not collect, and has no technical means by which to collect, the User's name, electronic mail address, telephone number, mailing address, precise or coarse geolocation, contacts, photographs, audio recordings, health or fitness information, financial information, or any category of sensitive information howsoever described under the Applicable Privacy Laws. Configuration and progression data, including without limitation game settings, difficulty selections, unlocked content flags, cosmetic selections and cumulative results (collectively, "Local Data"), are stored exclusively within the local storage container allocated to the relevant Application by the operating system of the Device, are not transmitted to the Company, and are deleted upon uninstallation of that Application by the User.

6. ADVERTISING; COLLECTION BY THIRD PARTY ADVERTISING PROVIDER. The Applications are provided to the User at no monetary charge and are supported by the display of advertising content served by the Third Party Advertising Provider through software development kits incorporated into the Applications. In connection with the serving, delivery, rendering, capping, frequency management, attribution and measurement of such advertising content, the Third Party Advertising Provider collects, receives and processes information from the Device, including without limitation: (a) the Advertising Identifier and other device-level identifiers; (b) information concerning advertising content presented to the User, including impressions, interactions, dismissals and completion events; (c) product interaction and usage information relating to the relevant Application; and (d) diagnostic information, including crash logs, launch times, hang rates and energy utilization measurements. The foregoing information may be combined by the Third Party Advertising Provider with information obtained from other applications, websites or sources for purposes of advertising personalization and advertising measurement, which combination constitutes "tracking" as that term is used in the App Store policies promulgated by Apple Inc. The Company does not itself receive, access, store or process the information described in this Section 6, and does not link such information to the identity of any User. The collection, use, disclosure and retention of such information by the Third Party Advertising Provider is governed by the privacy policy and related terms of the Third Party Advertising Provider and not by this Policy, which policy is available at https://policies.google.com/privacy and, with respect to information collected through partner services, at https://policies.google.com/technologies/partner-sites.

7. USER CONTROLS RESPECTING ADVERTISING IDENTIFIER. The operating system of the Device provides the User with the ability to grant or withhold permission for an Application to access the Advertising Identifier. Upon initial launch of an Application, the User is presented with the App Tracking Transparency authorization request prescribed by Apple Inc. The User may grant or decline such authorization in the User's sole discretion, and may thereafter modify such election at any time through the Settings application of the Device under Privacy & Security, Tracking. Withholding or revoking such authorization does not cause advertising content to cease being displayed, but will result in such advertising content being less personalized. The User may additionally reset the Advertising Identifier through the Settings application of the Device. Where the User is located within the European Economic Area, the United Kingdom, or any other jurisdiction in which consent is required as a condition of personalized advertising, the relevant Application presents a consent management interface prior to the enabling of personalized advertising, and the User may withdraw or modify such consent at any time through the means made available within that Application.

8. MULTIPLAYER FUNCTIONALITY; GAME CENTER. Certain Applications offer turn-based multiplayer functionality operated through the Game Center service provided by Apple Inc. Where the User elects to utilize such functionality, Apple Inc. authenticates the User, assigns and manages player identity, and transmits match state between participating Users. The nickname associated with the User's Game Center account is disclosed to the opposing participant in any match in which the User participates. The collection, use, disclosure and retention of information by Apple Inc. in connection with Game Center is governed by the privacy policy of Apple Inc., available at https://www.apple.com/legal/privacy/, and not by this Policy. Match state transmitted through Game Center consists solely of game state and move history, does not include free-form text, messaging or chat of any kind, and is not received, retained or accessible by the Company.

9. NO SALE OR SHARING OF PERSONAL INFORMATION. The Company does not sell Personal Information, does not share Personal Information for cross-context behavioural advertising within the meaning of the California Consumer Privacy Act as amended, and does not disclose Personal Information to data brokers. The Company holds no Personal Information capable of being sold, shared or disclosed.

10. CHILDREN. The Applications are intended for a general audience and are not directed to children under the age of thirteen (13) years. The Company does not knowingly collect Personal Information from children under the age of thirteen (13) years. In the event that the Company becomes aware that Personal Information has been collected from a child under the age of thirteen (13) years, the Company shall take commercially reasonable steps to address the same. A parent or guardian who believes that a child has provided Personal Information in connection with any Application may contact the Company at the particulars set out in Section 13.

11. RIGHTS OF USERS. Subject to and in accordance with the Applicable Privacy Laws, and depending upon the jurisdiction in which the User is resident, the User may possess certain rights in respect of Personal Information relating to the User, including without limitation rights of access, rectification, erasure, restriction of processing, objection to processing, data portability, withdrawal of consent, and non-discrimination in respect of the exercise of such rights. The User acknowledges that, by reason of the matters described in Section 5 hereof, the Company holds no Personal Information relating to the User and accordingly is generally unable to give effect to any such right by way of retrieval, correction, portability or erasure. Requests in respect of information collected by the Third Party Advertising Provider should be directed to the Third Party Advertising Provider by the means identified in Section 6. The Company shall provide reasonable assistance to any User seeking to exercise such rights.

12. RETENTION; AMENDMENT. The Company retains no Personal Information and accordingly maintains no retention schedule in respect thereof. Local Data persists on the Device until such time as the User deletes the relevant Application or clears that Application's data by means made available by the operating system. The Company reserves the right to amend, modify, supplement or replace this Policy at any time and from time to time in its sole discretion, including without limitation in response to changes in the functionality of any Application, the release of additional Applications, changes in the identity or practices of the Third Party Advertising Provider, or changes in the Applicable Privacy Laws. Any such amendment shall be effective upon posting of the amended Policy at the uniform resource locator at which this Policy is published, and the effective date set out above shall be revised accordingly. Continued use of any Application following any such posting constitutes acceptance of the Policy as amended.

13. CONTACT. All inquiries, requests and communications concerning this Policy or the privacy practices described herein may be directed to the Company as follows: Forester Games, a division of Forester Consulting Canada Incorporated, Georgetown, Ontario, Canada; electronic mail: dan@foresterconsulting.ca.

14. GOVERNING LAW. This Policy and any matter arising in connection herewith shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to conflict of laws principles, provided that nothing in this Section shall operate to deprive any User of the protection of any mandatory provision of the Applicable Privacy Laws of the jurisdiction in which such User is resident.