# Privacy Policy ## Privacy Policy **Sigma10 Games Co., Ltd.** and its affiliates (hereinafter referred to as “we”, “us”, or “the Company”) are committed to protecting the privacy and security of the information we collect and being transparent about the ways in which we collect and process your information. This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from or about you when you use the **mobile games and related services provided by us** (collectively, the “Services”). Our Services may include **Play-to-Earn** (P2E) elements and provide functions to exchange rewards obtained through in-game activities (gameplay, watching advertisements, participating in various contents and events, etc.) for virtual assets (such as USDT). Accordingly, this involves the collection of additional information such as blockchain wallet addresses. ### 1. Types of Data Collected We collect the following data to provide the Services: #### 1.1. P2E and Virtual Asset Related Information * **Virtual Asset Wallet Address (Public Wallet Address)**: The public address of the virtual asset wallet connected by the user. * **Transaction Records**: Records of token swaps, payout requests, and transaction hashes (Tx Hash) on the blockchain. * *Note: We do NOT collect or store your Private Key or Mnemonic phrase regarding your assets.* #### 1.2. Game Play and Event Participation Information * **Game Content Usage Records**: Records of participation in various events and probabilistic content (Roulette, Lotto, etc.), and history of winnings and reward payouts. * **Advertising Activity**: Number of ads watched and reward payout logs. * **Referral Information**: Referral codes and invitation reward history. #### 1.3. Identification and Device Information (Automatically Collected) * Device information (Model, OS version), Geography/Region. * Unique device identifiers for advertising (Google Advertiser ID or IDFA). * Universally Unique Identifier (UUID), Access IP address. ### 2. Purposes of Processing The collected data is used for the following purposes: 1. **Service Provision and Operation**: Providing game content, user management, and P2E reward payout and settlement (USDT exchange, etc.). 2. **Analytics and Testing**: Monitoring web traffic, analyzing user behavior, and testing content performance. 3. **Advertising**: Providing personalized advertisements based on user interests and measuring performance. 4. **Legal Obligations and Security**: Complying with legal obligations, preventing fraud, and detecting abuse. ### 3. Detailed Information on the Processing of Personal Data We use the following third-party services for the operation of our Service. The detailed processing information for each category is as follows: #### 3.1. Advertising To provide advertisements tailored to user interests, the following partners may process Trackers and Usage Data: * **Partners**: Unity Ads, AdMob (Google), ironSource, InMobi, Fyber, Pangle, PubMatic, Smaato, Mintegral, AppLovin, Chartboost, Google Ad Manager, BidMachine, VERVE. #### 3.2. Content performance and features testing (A/B testing) The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application. * **Firebase Remote Config**: An A/B testing and configuration service provided by Google LLC. #### 3.3. Platform services and hosting These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. * **Google Play Store and Apple App Store**: Platforms for the distribution of mobile apps that collect Usage Data, etc. #### 3.4. Analytics The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior. * **Unity Analytics and Google Analytics for Firebase**: These services process Usage Data and device information to perform analytics. #### 3.5. Infrastructure monitoring This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved. * **Crashlytics**: A monitoring service provided by Google Ireland Limited that processes crash data, etc. #### 3.6. Blockchain Network (Public Ledger) For the transparency of virtual asset transmission, wallet addresses and transaction history are recorded on the following network: * **Network**: BNB Chain (Binance Smart Chain) or other blockchain networks supported by us. * **Note**: Due to the nature of the blockchain, recorded information can be viewed by anyone worldwide and cannot be modified. ### 4. Legal Basis of Processing and Retention Time #### 4.1. Legal basis of processing The Owner may process Personal Data relating to Users if one of the following applies: * Users have given their consent for one or more specific purposes. * provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; * processing is necessary for compliance with a legal obligation to which the Owner is subject; * processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; * processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. #### 4.2. Further information about retention time Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore: * Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. * Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period. (However, transaction information recorded on the blockchain cannot be deleted due to technical characteristics.) ### 5. The Rights of Users #### 5.1. The rights of Users based on the General Data Protection Regulation (GDPR) Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law: * **Withdraw their consent at any time**: Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. * **Object to processing of their Data**: Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. * **Access their Data**: Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. * **Verify and seek rectification**: Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. * **Restrict the processing of their Data**: Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. * **Have their Personal Data deleted or otherwise removed**: Users have the right to obtain the erasure of their Data from the Owner. * **Receive their Data and have it transferred to another controller**: Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. * **Lodge a complaint**: Users have the right to bring a claim before their competent data protection authority. #### 5.2. Details about the right to object to processing Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. However, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. #### 5.3. Information on opting out of interest-based advertising In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US), the Digital Advertising Alliance (US), or other similar initiatives. Users may also opt out of tracking via applicable device settings (e.g., resetting the advertising ID). ### 6. Further Information for Users in Specific Regions #### 6.1. Further information for Users in the United States (US State Laws) Identifiers and internet or other electronic network activity information collected in the past 12 months have been used for advertising and analytics purposes, which may constitute a "Sale" or "Sharing" under applicable laws. In addition to the right to access data, Users have the right to opt out of the Sale or Sharing of their Personal Information. #### 6.2. Further information for Users in Brazil (LGPD) According to the LGPD, Users have the right to obtain confirmation of the existence of processing, anonymization, blocking or elimination of unnecessary or excessive personal information. ### 7. Contact Information (Data Controller) Any requests regarding data processing or the exercise of user rights can be directed to the Owner through the contact details provided below. * **Owner**: Heesung * **Contact Email**: --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. 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