We are a technology company dedicated to the design and development of mobile games. This Privacy Policy aims to clearly explain how and why we collect, store, share, and use your personal data, ensuring that all our operations are in compliance with the laws of the countries where we conduct business.

This Privacy Policy applies to our websites, mobile applications, marketing and advertising activities across all platforms, and other services we may offer you from time to time (collectively referred to as the "Services").

We act as the controller of the personal data we hold about you in relation to your use of the Services. This means we determine and are responsible for how your personal data is used. Once you download our mobile applications, access and/or play our games, or interact with our Services, your personal data will be processed to provide the Services, as per this Terms of Service & Privacy Policy.

Information Collection

Personal Data Collected Directly from You

We process your personal data to provide the Services when you download, access, and/or play our games or use our other Services. Most of this data comes directly from you. We collect the following information you provide in connection with our Services:

• Information Collected via Customer Support Channels: When you interact with us through our customer support channels, we may ask you to provide your username, email address, and any other information you choose to offer to assist us, such as Game ID, team/club name, device brand and model, advertising ID, transaction records, and device language.

• Information Provided During Gameplay: When you play our games, we might ask you to select a username.

• Feedback and Ratings: The feedback and ratings you give regarding our Services.

We use this data to provide you with our games and Services, including optimizing our Services, customizing in-game offers, and verifying purchases. We may also use it for other purposes described in this Privacy Policy.

Automatically Collected Information through the Services

To enhance and improve the Services for you, we gather several types of information for various purposes, including:

• Log Information: We record details about your use of the Services, such as the type of device you use, the features you utilize, access times, and your location based on your Internet Protocol ("IP").

• Device Information: We collect information about the device you use to access the Services, including the device manufacturer, model, operating system, time zone, and language of the device.

• Device Identifiers: We collect online identifiers of the device you use to access the Services, such as IDFA, Google Ads ID, and Google Play Account ID.

• Usage Information: We collect data related to your use of the Services, like your game progress, scores, achievements, and interactions with other players.

• Consumption Information: We gather information about your consumption habits when using the Services, including your purchases with virtual and real currencies and the receipt of virtual goods in-game.

Information Collected from Third-Parties

If you log into the Services using a third-party site or platform like Facebook, Apple Game Center, or Google Sign-In, we will access information about you from that site or platform, in accordance with the authorization procedures set by the third-party. This is provided that you have given consent to the third-party site. The information we may access includes your screen name, profile information, and friend lists.

You can learn more about how these third-party sites or platforms process your personal data through their relevant privacy policies:

• Facebook: https://www.facebook.com/about/privacy/

• Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/

• Google Play Games: https://policies.google.com/privacy

If you log into the Services using a third-party site or platform, you represent and warrant that your access and use of these features in relation to the Services will comply with the applicable terms and policies of that site or platform. Also, you confirm that you are above the minimum age limit set by the relevant legislation for that third-party site or platform.

Use of Information - Purpose and Legal Basis

We use information about you for the following purposes, in accordance with the legal requirements for each type of personal data:

• Service and Game Experience Provision and Maintenance: To provide and maintain the Services and the game experience.

• Game Provision and Support: To ensure the delivery of our games (Services), activate your purchases in the games, and offer player support if needed.

• Service Optimization: To optimize the Services for you and the device you are using, and to deliver customized in-game events, offers, and promotions.

• App-Related Communication: To communicate with you regarding App-related information, such as confirmations, technical notices, updates, security alerts, and support and administrative messages.

• Service Personalization and Improvement: To personalize and enhance the Services, and provide tailored content and features.

• Customer Interaction: To respond to your comments and inquiries and offer customer support services.

• Analysis and Service Enhancement: To collect analysis or valuable information to improve our Services.

• Trend, Usage, and Activity Monitoring: To monitor and analyze trends, usage, and activities related to the Services.

• Technical Issue Resolution: To detect, prevent, and resolve technical issues and bugs. Promotional and Product/Service Communication: To provide you with news, special offers, and information about other products, services, and events similar to those you've previously purchased or inquired about, unless you've opted out of receiving such information. Player Communication: To enable players to communicate with each other in games or on our social media accounts.

• Advertising: To serve advertising.

• Product and Service Delivery: To provide and deliver the products and services you request and send you related information.

• We only process your information to the extent necessary to achieve the purposes for which it was collected.

Information Storage

Your information will be retained for as long as is necessary to provide you with the Services or fulfill the purposes mentioned above, unless further storage is required to establish, exercise, or defend a legal claim, or to comply with applicable laws, including accounting regulations.

Information Sharing

Based on the legal bases under Sections 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR (as described above), we disclose information about you to the following recipients:

• Social networks, see more under "Social Sharing features".

• Third Parties: When required by applicable law, rule, regulation, legal process, or in connection with any merger, sale of company assets, financing, or acquisition of all or part of our business by another company.

• Authorities: If we believe your actions are inconsistent with our policies or if disclosure is necessary to protect the rights, property, and safety of us or others.

• Other Players: To enable certain in-app features like leaderboards, when you log into the Services using a third-party service.

Additionally, if you have given your consent as per Section 6(1)(a) of the GDPR, we share your device identifiers with advertising network companies for them to serve you behavioral advertisements within the Services.

Social Sharing Features

The Services offer or may offer social sharing features and other integrated tools (such as the Facebook "Like", "Share" button), which allow you to share your actions within the Services with other media. You must be over the minimum age limit specified by the legislation in each jurisdiction to use these social sharing features. Depending on the settings you configure with the entity providing the social sharing feature, using these features enables information sharing with your friends or the public.

Children's Policy

Use of the Services is restricted to users aged 13 years and above, except in the European Economic Area where it is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the Services, you warrant that you are 13 (or 16, depending on the applicable age) or older.

If you have any additional questions regarding our privacy practices related to children under the applicable minimum age, please contact us.

Security

The security of your data is of utmost importance to us. However, please note that no method of data transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your personal data, we cannot guarantee its absolute security.

Push Notifications

If you have agreed to receive push notifications, we will send game-related information, service updates, promotional messages, and other relevant notifications or alerts to your mobile device. You can disable these notifications by adjusting your device's notification settings.

Payments

We may offer paid products and/or services within the Services. In such cases, we use third-party services for payment processing (e.g., payment processors).

We do not store or collect your payment card details. This information is provided directly to our third-party payment processors, whose use of your personal information is governed by their respective privacy policies. These payment processors adhere to the standards set by PCI-DSS, managed by the PCI Security Standards Council, which is a collaborative effort of brands such as Visa, MasterCard, American Express, and Discover. The PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Apple Store In-App Payments. Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/.

• Google Play In-App Payments. Their Privacy Policy can be viewed at https://policies.google.com/privacy.

You agree to pay all fees and applicable taxes incurred by you or anyone using an account registered to you. We may revise the pricing of the goods and services offered through the Service at any time. YOU ACKNOWLEDGE THAT WE ARE NOT OBLIGED TO PROVIDE A REFUND OR ANY FORM OF COMPENSATION FOR UNUSED VIRTUAL RESOURCES WHEN AN ACCOUNT IS CLOSED, WHETHER THE CLOSURE IS VOLUNTARY OR INVOLUNTARY.

Your Rights

• Right of Access: You have the right to access information about you and receive an explanation of how we use it and with whom we share it. However, this right is not absolute. For example, we cannot disclose trade secrets or information about other individuals.

• Right of Erasure: You have the right to request the deletion of your information. We may need to retain some of your information when there are valid reasons under data protection laws. For instance, for the defense of legal claims, respecting freedom of speech, or when we have an overriding legitimate interest. We will inform you when this is the case. Note that if the information is held by a third-party data controller, such as an advertising partner or a payment processor, we will take reasonable steps to inform them of your request. But we recommend you contact them directly according to their privacy policies to ensure the deletion of your personal data.

• Right to Object and Withdraw Consent: You have the right to withdraw your consent if you previously provided it, or object to our processing of your information when we process it based on our legitimate interests (as described above regarding how we use your personal information).

• Right of Portability: You have the right to receive a copy of the information we process based on consent or contract in a structured, commonly used, and machine-readable format, or request that such information be transferred to a third party.

• Right of Correction: You have the right to correct any inaccurate information we hold about you.

• Right of Restriction: Under certain circumstances, you have the right to stop us from processing your information, except for storage purposes.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and change the date at the beginning of the policy. If we make significant changes, we will notify you via email to your registered email address, prominent display on our Services, or other appropriate communication channels. Any new policy will take effect from the date of its publication.

If you have any questions about this Privacy Policy, want to know more about why, how, and what personal data we use, or wish to request the deletion of your data, please contact us at [email protected].