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PRIVACY POLICY

(Effective Date: 1^st February 2025)

GRAVITY GAME HUB (GGH) PTE LTD (“Company,” “We”, “Us” or “Our”) maintains this Privacy Policy (“Privacy Policy”) that summarizes our policies and processes on how we collect, use disclose, transfer and store your personal information. The Privacy Policy applies only to the collection, use and storage of personal information that you may decide to provide to us in your use of:

(1) Our website(s) (our “Sites”),
(2) Our applications for mobile platforms or devices and our web applications accessible on social networking services (“SNS”) (collectively, our mobile and web applications are referred to herein as, the “Applications”),
(3) Our game publisher networks, crowd sourcing service and platforms (collectively, “Networks”) provided in connection with Applications and third-party applications utilizing our Services (“Third Party Mobile Applications”) and
(4) Chat rooms, blogs, web forums, messaging boards or other public forums in Applications and our Sites (collectively, our “Forums”).

The Applications, Networks, Sites, and Forums are referred to herein collectively as the “Services”.

Our Services are offered globally, including throughout Europe (EEA and UK). However, please be advised that residents of CIS countries, including but not limited to Russia, Kazakhstan, Belarus, Kyrgyzstan, Tajikistan, Turkmenistan, Uzbekistan, Armenia, Azerbaijan, and Moldova, are excluded from our Services. We do not provide Services to or process personal information of users in these CIS territories.

Therefore, if you are a resident of any CIS country:

*  You are not permitted to access, use, register for, or participate in any of our Services.

*  Any access or use from CIS countries is unauthorized.

*  If you subsequently acquire residency or citizenship in any CIS country, you must promptly notify us so that we may terminate your access in accordance with our Terms of Service and this Privacy Policy.  

By accepting our Privacy Policy and the applicable Terms of Service during Service account registration or by otherwise accessing or using our Service(s) you are agreeing to the terms and conditions of this Privacy Policy (including our collection, storage, use and disclosure of your personal information) and that your access or use of the Service(s) is also subject to the applicable Terms of Service.

Collecting Personal Information

Our primary goal in collecting the information described below is to provide you, the user, with a customized experience on our Service and to deliver better service, products, and more relevant content to our customers, prospective customers, and visitors.

1. Personal Information We Collect
   
   

Personal information may be collected from you during your use of the Service, including, during (a) the registration process, (b) promotional campaigns, (c) customer support and technical service requests, and/or (d) ordering and use of products and other services, or from and through third party service providers and partners.

Information Collected Directly From You

Registration Information. When you communicate directly with us, either through an Application, at our Site, a Network or Forum, you are authorizing us to collect, store and use/share information collected from you in accordance with this Privacy Policy. Such information may include:

(i) Your valid e-mail address;
(ii) Password and other information necessary to ensure security of your account; and
(iii) Such other information you choose to provide to us such as billing information, profile photo, photo representation (avatar), character name, interests and hobbies, game play preferences, and links to profiles on various SNS.

From time to time we may expand or change the information requested upon registration or log-in, so this may not be a complete list. We ask that you provide only your own personal information, not personal information concerning anyone else.

Usage Information. We collect details of your use of our Services and the resources that you access. Such usage information include information about how and when you access or use our Services (such as Games accessed, game score, pages visited, purchase and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your game play).

Interaction and Communications among Users. We collect information about

(i) Your interaction with other users (for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and
(ii) Your communication and interaction with your contacts through social media channels (including, social network services, messengers, and any other services which has social features like invite friends and sharing information with friends).

Information Through Mobile Devices. When you use an Application or Third Party Mobile Application on your mobile telephone or other mobile devices (“Mobile Device”), in addition to such information described above, you are authorizing us to collect, store and use/share the following information (as applicable):

(i) Mobile device type;
(ii) Mobile carrier;
(iii) Internet Protocol address;
(iv) Geographic location/country;
(v) Platform version;
(vi) Navigation, interaction and engagement information regarding our users
(vii) MAC address, International Mobile Equipment Identity (IMEI), display resolution, time and date on screen of Mobile Devices and;
(viii) Such other information you choose to provide to us. In addition, we receive and store information you provide when you sign up to have Short Message Service (“SMS”) notifications set directly to your Mobile Device.

Payment and Billing Information. If you purchase any in-Service items, our third party partners will collect the payment and billing information necessary to complete the transaction. Such information may include:

(i) Your first and last name;
(ii) Your valid e-mail address;
(iii) Credit card, PayPal and other third party payment processor information;
(iv) Billing address; and
(v) Such other information you choose to provide. Our third party partner may also receive the foregoing information that you provide when you purchase Applications and Third Party Mobile Applications through your Mobile Device.

Customer Service and Support. When you send email or other communications to us in connection with customer service and support, we will collect and store your contact information, information about your use of the Service, your user ID and such other information you provide to us in order to process your inquiries, respond to your requests and improve our Service. We will also store the correspondence and any information contained therein.

Profile Information. We provide areas on our Service where you can post information about yourself and others and communicate with others or upload content such as photographs. Such postings are governed by the applicable Terms of Service. In addition, such postings may appear on other websites or services, or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable areas, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

Information Received from SNS and APIs

When you use an Application at an SNS, you allow us to access certain information from your profile through such SNS and the applicable SNS platform Application Programming Interface (“API”). The information we receive varies by the Application and by the privacy settings you choose for the SNS and may include any or all of the following information, as allowed by you, the SNS and your privacy preferences:

(i) Your first and last name;
(ii) Your profile picture or its URL;
(iii) Your user ID number; which is linked to publicly available information such as name and profile photo;
(iv) The user ID numbers for your friends that are also connected to our Application(s);
(v) Login e-mail you provided to the SNS when you registered;
(vi) Your physical location and that of your access device(s) and
(vii) Your gender.

By using our Application(s) through an SNS, you are authorizing us to collect, store and use/share any and all information you agreed the SNS could disclose to us through the API in accordance with this Privacy Policy. Your agreement is evidenced when you “accept” or “allow” (or comparable terms) one of our Applications on an SNS.

2. How We Collect Personal Information
   
   

Automated Information Collection Technologies
As described below, when you access our Services, we collect certain technical information and may associate such information with your user or account ID number for our internal use.

Cookies

Automated Information Collection Technologies
As described below, when you access our Services, we collect certain technical information and may associate such information with your user or account ID number for our internal use.

Cookies

A “cookie” is a small text file that is sent to your browser from a web server and stored on your computer’s hard drive. We may use cookies to track general, non-personal information about our users (e.g., user name, pages viewed, time spent on our Site(s), games, and the sites visited just before and just after our Site(s)) for statistical and market research purposes.

We use cookies to gather information about our users’ browser activities in order to constantly improve our Service. This information assists us to design and arrange our web pages in a most user-friendly manner and to continually improve our Service to better meet the needs of our customers, prospective customers, and visitors.

We may also use local shared objects known as “flash cookies”, which help us to prevent fraud, remember your in-game settings and to track your progress on certain in-game tasks.

You have choices with respect to cookies. By modifying your browser preferences, you have the option to reject all cookies, or limit the type of cookies you allow. Flash cookies operate differently from browser cookies and cookie management tools available in a web browser will not remove flash cookies. To learn more about and manage flash cookies you can visit www.adobe.com. Rejecting or limiting the type of cookies may, however, in limited instances prevent you from accessing certain features on our Service.

Log Files

Like most Internet services, we may also use log files on the server side. The data held in log files includes your computer’s or Mobile Device’s IP (Internet Protocol) address, browser type, browser language, e-mail application, Internet service provider, referring/exit Web pages, computer platform type, date/time stamp, and user activity. Company uses server log data to analyze trends, administer the services offered through our Service. We and our third-party partners may use this information for product and service improvements, and in marketing and advertising services.

The software enabling our Services has associated log and temporary files that are stored on Company’s servers. These files store your account information, preference settings, system notifications as well as other data necessary to enable you to participate on our Service. Your information may also exist within regularly performed server backups.

Tracking Technologies

Our Services may utilize a variety of methods for tracking purposes, including web beacons (also known as Internet tags, pixel tags and clear GIFs). Web beacons are small pieces of data that are embedded in images on the pages of websites to analyze the traffic patterns, such as the frequency users visit various areas of our Services. Pixel tags may allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation. These methods may involve transmitting information either directly to us or to another entity authorized by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we send our guests to determine whether our guests have opened those e-mails or clicked on links in those e-mails. With web beacon technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.

Third Party Advertisers

Many advertisements are managed and placed on the service by third parties. These third-party advertisers may use cookies, web beacons or similar automated information collection technologies on your computer or Mobile Devices to help present, better target, and measure the effectiveness of their advertisements, by collecting non-personally identifiable information when you click on or move your cursor over one of their advertisements. We may share certain non-personally identifiable information about you as a user with certain third-party advertisers to help them deliver more relevant advertisements through their ad networks. In some cases, we may have access to information from cookies, web beacons and similar automated information collection technologies used by third party advertisers on our Services and this information may permit us to identify other sites or services that you have visited that are also associated with the third-party advertiser.

The use of cookies, web beacons, or similar automated information collection technologies by third party advertisers is subject to their own privacy policies. Finally, once you have clicked on an advertisement and have left the Service, our Privacy Policy no longer applies and you must read the privacy policy of the applicable third-party advertiser to see how your personal information will be collected, stored and used as part of their service.

Click Through URLs

Some of our Services, including email messages, use “click-through URLs” linked to other content on our Services. We track this click-through data to help us determine interest in topics and use of the Services.

Monitoring/Public Information
You may also choose to disclose personal information in our Forums. Personal information you disclose in such Forums is public information, and there is no expectation of privacy or confidentiality. Please refer to the Terms of Service for additional information relating to the disclosure of personal information in such Forums.

Other Sources
We may collect or receive information from other sources including other users of the Service and third-party information providers and partners. For example, we receive and store the information you provide when you enter any promotion, sweepstakes or loyalty program. Such information may be used to supplement your account information and/or profile and may be combined with other information we collect from you.

Use, Disclosure and Transfer
Unless otherwise described elsewhere in this Privacy Policy, we will not use or disclose any personal information collected from you. Your personal information may be used alone or in the aggregate with information collected from other users.

Use by Company

We use the information you provide so that we may better understand your needs and the needs of our customers, prospective customers, and visitors. Specifically, we use your personal information for many purposes, including:

(a) To allow you to register for and use our Services;
(b) To apply for employment opportunities at the Company;
(c) To audit and analyze data to improve and ensure the continued smooth operation of our Service;
(d) For market research purposes, including, without limitation, to analyze user characteristics and usage patterns in order to better understand how our Services are used and market them more effectively;
(e) To communicate with you concerning your account or to send you announcements, newsletters, promotional materials and other information about our Services or offerings of our business partners, and to offer you opportunities to participate in surveys, contest and sweepstakes; *
(f) To prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Service;
(g) To respond to inquiries, troubleshoot problems, investigate incidents, and handle complaints;
(h) Provide, maintain, protect and improve our Services, including keeping you posted on our latest Service announcements, software updates and upcoming events, and develop new services;
(i) Protect our rights or property or that of our users;
(j) To satisfy any applicable law, regulation, legal process or enforceable government request;
(k) To send notices, such as communications about your purchases and changes to our Terms of Service, this Privacy Policy and other Service-specific policies, and to enforce applicable terms and conditions set forth in such policies;
(l) To enable user-to-user communications; and
(m) Protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.

The Company processes personal information on our databases, equipment and servers (owned by the Company and/or third parties in other countries). In some cases, we may process personal information outside of your country.

* If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or follow the process described in the “Opt-Out Provision” section below

Disclosure and Transfer to Third Parties

We generally do not disclose or transfer any personal information about our customers, prospects, or visitors to any third parties. We may however, disclose and transfer data which does not contain or reveal any personally identifiable information or is specifically attributable to you to our business partners, third party analytics service providers, ad networks and advertisers (collectively, “Partners”). Provided, however, some Partners may also act as third party service providers (described below) to us and may have access to your personally identifiable information. Moreover, Partners may obtain public information about you from your profile or other public sources.

We may also periodically engage in co-marketing activities, where we work with a complementary solution provider to launch a joint marketing program. In these situations, we will only send information to you on behalf of the other; we do not provide your personally identifiable information to such partner. We may also enter into business partnerships with other parties to provide specific services. If a user signs up for these services or responds to a particular marketing offer, we may share personally identifiable information such as your name or other contact information that is necessary for our business partner to provide these services or get in contact with you.

Disclosure of your personally identifiable information may occur when we engage or employ service providers, vendors or other third parties to facilitate the provision of our Services (including, without limitation, payment processing, data analysis, e-mail delivery, hosting services, customer service and promotional services) to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Such third party service provider (“Third Party Partner”) may have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Currently, the name of Third-Party Partner, services performed by it on our behalf, service territory of it, and period of retention and use by it of Personal Information are as follows:

In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your personally identifiable information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to the Company’s privacy practices will occur as a result of such transaction, we will notify you and other users in the manner described in this Privacy Policy.

In addition, upon the expiration or termination of any third-party license arrangements involving one or more parts of the Service, your personal information (including name, email address and other personally identifiable information) may be transferred to the subject third party licensor in accordance with the terms of the applicable license agreement. In advance of such transfer to a third-party licensor, the Company will notify you and other users in writing in the manner described in this Privacy Policy.

Safety, Security and Legally Required Disclosures

Your personally identifiable information, and communications you make within the Service, may be accessed and disclosed if we believe that our Service is being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our Terms of Service, or for us to render the service you have requested.

We may also disclose personally identifiable information when required by law, regulation, court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally required disclosures to government authorities and provide notice to you of any breach of security, confidentiality or unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.

Storage and Security
We employ reasonable measures (both online and offline) to protect the security of information we collect from you. Such information is housed in secure databases, equipment and servers located in the Thailand and/or in other countries. The databases, equipment and servers we utilize may be owned by third party providers. To prevent unauthorized access, loss, or misuse, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we maintain. We use industry-standard technology, such as firewalls, in an effort to protect the confidentiality of your personal information. Moreover, in addition to password protection offered in connection with your Service account, we encrypt your transmission of sensitive information to us (e.g., account passwords and payment-related identifiable information) via SSL (secured socket layer) protocol in the interest of heightened privacy protection and information integrity.

Although we take reasonable precautions against possible security breaches of our Service, databases, equipment or servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and factors beyond our control will never take place and result in disclosure of your personal information. Accordingly, we disclaim any guarantees, warranties or representations relating to maintenance or nondisclosure of any personal information collected from you. We strongly urge you to take reasonable measures at all times (online and offline) to protect your personal information, including your password and other sensitive information.

In addition, while we strive to protect your personal information, you should know that information sent over the Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception. Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information.

We will investigate, attempt to resolve and take all reasonable steps necessary to ensure that your personal information and data is treated securely and in accordance with this Privacy Policy.
We will retain your personal information for as long as is necessary to fulfill the purposes for which it was collected or as needed to provide you with Services. We may retain your personal information after you have closed any account you have with us or after we have ceased providing Services to you if retention of your Personal Information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between members, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.

Additional Privacy Policy Terms
Opt-Out Provision

When we first collect information from you, we will offer you the opportunity to opt-out of having your personal information shared with parties outside of Company (unless otherwise described in this Privacy Policy). In addition, if you do not want us to send you communications relating to our Services, including, without limitation, announcements, newsletters and promotional materials or offers to participate in surveys, contests or sweepstakes, you can opt-out at the time of registration or information collection. If, at a later date, you choose to have your name or any other personal information removed from our mailing list, you can do so by emailing support@gravitygamehub.com.

Review, Update, Correct, or Delete Personal Information

Generally, you may review, update, correct or delete your personal information collected by or through our Service by logging into your account. You may also correct factual inaccuracies. Certain types of personal information that is necessary to check eligibility, such as birth date or age, cannot be deleted, but may be modified with sufficient verification of the new information. Note that we reserve the right to terminate or delete any registration or promotional entry if we believe the personal information submitted was knowingly false or fraudulent.

To delete your personal information, you may also email us at support@gravitygamehub.com. We will use commercially reasonable efforts to honor your request.

Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others, including but not limited to any information that has been:

(i) incorporated into others user’s content, comments, postings, submissions, cities, resources or other in-game assets;
(ii) copied, stored or disseminated by other users;
(iii) shared or disseminated by you or others such as in a public posting; or
(iv) posted on a third party platform. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able and/or obligated to remove any of your information from a third party platform.

Moreover, please be aware that even after you delete your account or your account is terminated, your information is not deleted in its entirety from our servers and may not be deleted from servers of the third party platform you use to access our Services. We may, but are not obligated to, retain backup copies of your information, including personal information on our servers or databases (and/or any authorized third party servers or databases we use). Such information may be disclosed pursuant to this Privacy Policy regardless of whether your account is deleted or terminated. Moreover, any third party platform that you use to access the Services may also retain backup copies of your information even after your account is deleted or terminated which may be used and/or disclosed in accordance with their privacy policy.

To have access to your personal information, you must provide proof of identification such as full name, street address, city/state and zip code, user ID and password, and/or information about your recent activity on our Service. We reserve the right to deny access to any user if we believe there is a question about your identity. And if the burden or expense of providing access to your personal information is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide access to such information. Moreover, we may still retain an archived copy of your information in our files as required by law or for legitimate business purposes, including, resolving disputes, enforcing the Terms of Service, and for other technical and legal requirements and constraints related to our Service.

To manage the information we receive about you from the SNS where you play our games, you will need to follow the instructions at that SNS for updating your information and changing your privacy settings.

Notification of Changes

We reserve the right to update and change the terms of this Privacy Policy at any time. If we decide to update and materially change the terms of our Privacy Policy, we will post those changes in our Services and/or on the applicable Sites, and in the updated Privacy Policy. You should periodically check this Privacy Policy for updates.

By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you are agreeing to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.

Links to Third Party Websites, Services and Offers.

Our Service may contain links to other websites, services and/or offers from third parties. We are not responsible for, nor will it be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing personal information to them. Moreover, if you have any questions or concerns, you should contact the third party directly.

Protection of Children’s Privacy

Company is committed to providing special protection for the privacy of children who may use our Service. The Service is intended for or directed to ALL ages.

Special Note to Parents

If you become aware that your child has provided us with personal information at our Service, we invite you to notify us so that we may delete the information from our records and discontinue any related features or services (see Opt-Out Provision above). We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

Users Outside Singapore

The Company is a Singapore company and Company’s business operations are primarily conducted in Singapore. We operate our company and administer this Privacy Policy under applicable laws and regulations of Singapore. If you use our Service from outside Singapore, you are thereby consenting for your personal information to be transferred to, stored in and be processed in the Singapore and/or in other countries by the Company and/or its Affiliates in the manner described in this Privacy Policy. Your consent to this Privacy Policy followed by your submission of your personal information represents your agreement to such transfer, storage and processing of information.

As described elsewhere in this Privacy Policy, when you submit personal information via our Service, the information is housed in secure databases, equipment and servers located in the Thailand and/or in other countries. The databases, equipment and servers we utilize may be owned by third party providers.

Users in certain jurisdictions may have a right to access his/her personal information held by the Company and/or its Affiliates. Your right of access to such personal information can be exercised in accordance with applicable laws, rules and regulations. Please submit any requests for such access to support@gravitygamehub.com.

Language

The controlling language of this Privacy Policy is English. If you have received a translation into any other language, it has been provided for your convenience only. The English version of this Privacy Policy shall govern to the extent of any inconsistency between the English version and any translated version.

Contact Us

If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Policy, or have other questions or suggestions about our information practices, please contact us via e-mail at support@gravitygamehub.com.

3. SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

(1) Additional Information for US Residents

(a) General

Why We Collect and Process Your Personal information

In order to provide our services to you, we collect and process the following categories of personal information described in more detail in Section 1, for one or multiple purposes described below, and for any other purposes for which we provide specific notice at the time the information is collected.

Data Retention

Where your data is required to be deleted in accordance with your request or where we are legally required to do so under applicable law or otherwise, we may retain certain personal information where permitted or required under law.

For example, we may retain persistent identifiers such as device ID, device FP, IP address and other device information that was collected prior to obtaining verifiable parental consent, for the purpose of supporting internal operations.

Your Rights and Choices

If you submit a request to us and you receive a response from us informing you that we have declined your request, in whole or in part, where provided by applicable law, you may appeal that decision by submitting your appeal using the contact method described in the ‘Contact Us” section of this Privacy Policy.

Right to Opt-out of Targeted Advertising and Data “Sales”

Some privacy laws define “sale” broadly to include some of the data disclosures described in Section 6 above – in particular certain sharing with third party providers for targeted advertising purposes. To opt-out from targeted advertising and any related data “sales,” you have several options.

You can use browser or device-level controls as follows:

Cookie controls

Please see our Cookie Policy in each our game websites for details on how you can control cookies.

Note that if you choose to refuse or delete cookies, this could affect certain features, settings and preferences controlled by those cookies including advertising preferences which may be deleted and may need to be recreated.

Do Not Track

Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the advertising controls described above.

Mobile advertising ID controls

iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

Email web beacon controls.

Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, and the automatic connection to the web servers that host those images

These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, take these actions from those devices or browsers to ensure your choices apply to the data collected when you use them.

(b) Additional terms for California Residents

California Consumer Privacy Act. The CCPA requires us to provide our users who reside in California with the additional notice below.

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

* Lawfully made available from government records.

* Deidentified or aggregated.

* Otherwise excluded from the scope of the CCPA.

We collect and disclose the categories of personal information as set out in Section 3(1)(a) above, for the business purposes also set out in Section 3(1)(a).

If you are a California resident, and the processing of personal information about you is subject to the CCPA, you have certain rights with respect to that information:

Notice at Collection.

At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Privacy Policy by referring to this and the above-referenced sections.

Right to Know

The right to request a copy of the personal information that we have collected about you in the prior 12 months. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this Privacy Policy. You may make such a “request to know” as described in Section 8(1) of this Privacy Policy.

Rights to Request Correction or Deletion.

You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions.

To make a request to correct or delete, please do so using our game/non-game account information functionality or email us using the contact information in the ‘Contact Us” section of this Privacy Policy.

Right to Opt-Out / “Do Not Sell or Share My Personal Information”

You have a right to opt-out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA. Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data disclosures described in this Privacy Policy may be considered a “sale” or “sharing” under those definitions.

In particular, we let advertising and analytics providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (Browse, clicks, app usage), and device data through our sites and apps when you use our online services, but do not “sell” or “share” any other types of personal information. If you do not wish for us or our partners to “sell” or “share” personal information relating to your visits to our sites for advertising purposes, you can make your request by emailing us using the contact information in Section 12 of this Privacy Policy.

If you opt-out using these choices, we will not disclose or make available such personal information in ways that are considered a “sale” or “sharing” under the CCPA. However, we will continue to make available to our partners (acting as our service providers) some personal information to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising.

We do not knowingly sell the personal information of minors under 16 years of age.

Right to Limit Use and Disclosure of Sensitive Personal Information.

You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. Note that we do not use sensitive personal information for any such additional purposes.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request through common market practices, including by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law. California Customers may request further information about our compliance with this law by emailing the address provided in the "Contact Us" section above.

Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.

California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, or to request that we remove such content or information, please send us a detailed description of the specific content or information you wish to have removed using the details provided in the "Contact Us" section above.

Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

An authorized agent may submit an access or deletion request on your behalf by sending a written authorization signed by you using the contact information in the “Contact Us” section.

We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request

(2) Additional Information for the EEA and UK residents

If you are in the European Economic Area (EEA) or the United Kingdom (UK), the following additional information applies to you in addition to the Privacy Policy set out above.

Data Subject Rights

In addition to the information set out in the "Your rights and choices" section in the Privacy Policy above, you have the right to:

* ask us to restrict the processing of your personal information,

* data portability,

* to object to the processing of personal information.

Legal basis for processing your personal information

Our legal basis for collecting and using the information described in section 1 for the purposes in section 2 of our Privacy Policy above is:

* To establish and perform our contract with you (i.e. our Terms of Service) and to provide our services;

* For our or our partners’ legitimate interests, where those interests are not overridden by your data protection interests of fundamental rights and freedoms, e.g. to protect our legal rights, to pursue or defend legal claims, to improve our services;

* Consent, where obtained separately;

* For compliance with our legal obligations under applicable laws and regulations;

* To protect our or your vital interests or those of another person (for example, another player), e.g. against fraud and violations of our terms;

While we typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of explicit consent or other applicable lawful basis.

Where we rely on a legitimate interest for the processing of your data, we have performed a legitimate interest assessment to determine whether your interests outweigh our interests in the processing taking place.

You can obtain more information about this balancing test by using the contact details under ‘Contact Us’.

If you have questions, need further information about the legal bases for processing your personal information, or want to withdraw your consent, please see section 12 “Contact Us” in the Privacy Policy above.

Cross-border data transfer

As a global company, we may transfer your personal information to our affiliates, third party service providers and partners that operate around the world, which are located in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable. Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, and/or the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR. This is how transfers of personal information between us and other companies will be safeguarded. All companies are required to protect personal information that they process from Europe in accordance with European Union data protection law. Transferred personal information includes basic information such as your name or contact information such as your email address.

When we transfer your personal information internationally, we comply with relevant laws and regulations, and we enter into Data Processing Agreements (DPA) or Data Sharing Agreements (DSA) with all third-party partners (data recipients) with whom we exchange data. These agreements include limitations on the purposes of personal information processing, implementation of security measures, and cooperation obligations for exercising your rights, incorporating appropriate safeguards such as European Union Standard Contractual Clauses (SCC). This ensures that your data receives a high level of protection even in the countries to which it is transferred.

[Supplement: DSA Related Content for Cross-Border Data Transfer]

Children's Notice

Our services are not marketed to, or intended for, children. Children for the purposes of our services are (a) under the age of 13 years old or, if older (b) between 13 and 18 years old but under the age at which they can give valid digital consent to processing of their personal information under applicable data privacy laws.

We strive to follow the different minimum age guidelines set by the laws of individual regions when determining the age that children can access certain features of our services. Children are not permitted to use our services, and we do not knowingly collect any personal information from children. Though our services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain services. If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under applicable privacy law, we will take measures to promptly remove that information from our records.

Data Protection Supervisory Authority

To lodge a complaint with your national or regional data protection supervisory authority, please contact the competent authority.

(3) Additional Information for Residents of Japan

If you are located in Japan, please see the information below with regard to international data transfers as described in Section 7 (Data Retention), in accordance with Article 28(2) of the Japanese Act on the Protection of Personal Information.

1. the name of the countries where the data recipients are located (headquartered): Singapore

1. the personal information protection systems of such foreign countries

See the link below: https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku

iii. the measures to be taken by the data recipients

We will ensure that third parties in foreign countries to which we transfer your personal information take all measures corresponding to the eight principles of the OECD privacy guidelines.

(4) Additional Information for residents of South Korea

If you are in South Korea, the following additional information applies to you in addition to the Privacy Policy set out above.

Destruction of Your Personal information

If we determine that your personal information is no longer needed, we will destroy it under the supervision of our chief privacy officer and in accordance with applicable law and the Privacy Policy.

Personal information in the form of electronic files will be securely deleted using technical methods to prevent recovery and reproduction, and printouts will be destroyed by shredding or incineration.

Data Subjects Rights

In addition to the information set out in the "Your rights and choices" section in the Privacy Policy above, you have the following rights:

1. Right to Request the Suspension of Processing

You may have the right to request the suspension of processing of your personal information that we have collected and processed. However, such a request may be denied under applicable laws or regulations. In many circumstances, we need to process your personal information in order to provide you with the services you require. If you do not provide the necessary personal information, or if you request the suspension of its processing for these purposes, we may be unable to continue providing you with the services you require.

Location of Servers

The servers for the services we provide are located as follows:

(5) Additional Information for Residents of Brazil

If you are a resident of Brazil, the following additional information applies to you in addition to the Privacy Policy set out above. The Brazilian General Data Protection Law (Lei Geral de Proteção de Dados, "LGPD") is a comprehensive law that applies to the collection and processing of personal information of residents in Brazil.

Data Subject Rights

In addition to the rights set out in the "Your rights and choices" section of the Privacy Policy above, under the LGPD, you have the following rights:

1. Right to Confirmation of Processing

The right to obtain confirmation of the existence of personal information processing.

1. Right to Access Data

The right to access your personal information.

iii. Right to Data Correction

The right to correct incomplete, inaccurate, or outdated data.

1. Right to Anonymization, Blocking, or Deletion

  The right to anonymize, block, or delete unnecessary, excessive data, or data processed in non-compliance with the LGPD.

1. Right to Data Portability

 The right to request the transfer of your data to another service or product provider, by express request and subject to commercial and industrial secrecy, in accordance with the national authority’s regulations. (Note: Data already anonymized by the controller is not subject to portability.)

1. Right to Deletion of Consent-Based Processed Data

 The right to delete personal information processed with your consent, except in situations provided in Art. 16 of the LGPD.

vii. Right to Information on Shared Entities

 The right to obtain information about public and private entities with whom the controller has shared data.

viii. Right to Information on Consent Denial and Consequences

 The right to obtain information about the possibility of denying consent and the consequences of such denial.

1. Right to Revoke Consent

 The right to revoke consent at any time, as provided in Art. 8, §5 of the LGPD.

1. Right to Review Automated Decisions

 The right to request a review of decisions made solely based on automated processing of personal information that affect your interests, including decisions intended to define your personal, professional, consumer, or credit profile, or aspects of your personality.

To exercise the above rights, please contact us using the contact details under “Contact Us” below. Requests are fulfilled free of charge, and access requests are responded to within fifteen (15) days from the date of the data subject's request.

Legal Basis for Processing Personal information

Under the LGPD, we may collect and process your data based on the following legal bases:

1. Your Consent

Free, informed, and unambiguous manifestation by which the data subject agrees to the processing of their personal information for a given purpose. (Consent must be given in writing or by other means capable of demonstrating the data subject's will, and written consent should be in a clause that stands out from other contractual clauses.)

1. Compliance with Legal or Regulatory Obligation

For compliance with a legal or regulatory obligation by the controller.

iii. Contract Execution

When necessary for the execution of a contract or preliminary procedures related to a contract of which the data subject is a party, at the request of the data subject.

1. Legitimate Interests

When necessary to fulfill the legitimate interests of the controller or a third party, except when the data subject's fundamental rights and liberties which require personal information protection prevail. (In this case, only strictly necessary personal information for the intended purpose may be processed.)

1. Protection of Life or Physical Safety

When necessary to protect the life or physical safety of the data subject or a third party.

1. Credit Protection

For the protection of credit, including as provided in specific legislation.

vii. Studies by Research Entities

For carrying out studies by research entities, ensuring, whenever possible, the anonymization of personal information.

Data Processing Agreement (DPA/DSA) and Partner Relationship

For the processing of personal information of Brazilian residents, we have entered into a specialized DPO service agreement with a professional DPO service provider, DPO Oficial (Vetaluti Consultoria e Assessoria Ltda.). This agreement ensures the DPO performs the duties specified in LGPD Article 41, and we are obligated to provide the DPO with all necessary information, documents, and resources to ensure LGPD compliance and protect data subject rights. We also implement technical and administrative measures for personal information security as outlined in our DPO service agreement.

International Transfer and Safeguards

The LGPD allows for the international transfer of personal information in certain cases, particularly when the receiving country or international organization provides an adequate level of personal information protection equivalent to LGPD provisions, or when the controller offers and proves guarantees of compliance with LGPD principles and data subject rights. These guarantees can be in the form of specific contractual clauses, standard contractual clauses, binding corporate rules, or regularly issued stamps, certificates, and codes of conduct. We utilize such legal mechanisms to ensure appropriate protection levels for personal information transferred from Brazil.

Security Measures

As personal information processing agents, we adopt security, technical, and administrative measures capable of protecting personal information from unauthorized accesses and accidental or unlawful situations of destruction, loss, alteration, communication, or any type of improper or unlawful processing, in accordance with LGPD Art. 46. These measures must be complied with from the conception phase of the product or service until its execution.