# Privacy Policy

Sigma10 Games Co., Ltd. and its affiliates (“we”, “our”, “us”, “the Company”) is 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. It applies to the Surfer Block Puzzle app and online services that we operate and that link to this Privacy Policy, such as the Surfer Block Puzzle, the blockchain services and online communities (collectively, the “Services”).

It is important that you read this Privacy Policy, together with any other notices we may provide on specific occasions when we are collecting or processing your personal data, so that you are aware of how and why we are using such personal data and what your rights are under the relevant data protection laws.

## Policy summary

#### Advertising

* #### Unity Ads and ironSource

  Personal Data: Tracker; Usage Data
* #### AdMob

  Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
* #### InMobi, Fyber, Pangle, PubMatic, Smaato, Mintegral, AppLovin, Chartboost, Google Ad Manager, BidMachine and VERVE

  Personal Data: Trackers; Usage Data

#### Content performance and features testing (A/B testing)

* #### Firebase Remote Config

  Personal Data: various types of Data as specified in the privacy policy of the service

#### Platform services and hosting

* #### Google Play Store and Apple App Store

  Personal Data: Usage Data

#### Analytics

* #### Unity Analytics

  Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service
* #### Google Analytics for Firebase

  Personal Data: Application opens; Application updates; device information; geography/region; In-app purchases; launches; number of sessions; number of Users ; operating systems; session duration; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

#### Infrastructure monitoring

* #### Crashlytics

  Personal Data: crash data; device information; Universally unique identifier (UUID)

### Information on opting out of interest-based advertising <a href="#opt_out" id="opt_out"></a>

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](http://www.youronlinechoices.com/) (EU), the [Network Advertising Initiative](https://thenai.org/about-online-advertising/) (US) and the [Digital Advertising Alliance](https://www.aboutads.info/consumers/) (US), [DAAC](http://youradchoices.ca/understanding-online-advertising) (Canada), [DDAI](http://www.ddai.info/optout) (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called [AppChoices](https://youradchoices.com/appchoices) that helps Users to control interest-based advertising on mobile apps.

Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

### Contact information <a href="#contact_information" id="contact_information"></a>

* #### Owner and Data Controller

  * #### Heesung Park
  * #### 9, Gangnamseo-ro, Giheung-gu, Yongin-si, Gyeonggi-do, Republic of Korea
  * #### Owner contact email: <support@sigma10games.com>

## Full policy

### Owner and Data Controller

* #### Heesung Park
* #### 9, Gangnamseo-ro, Giheung-gu, Yongin-si, Gyeonggi-do, Republic of Korea
* #### Owner contact email: <support@sigma10games.com>

### Types of Data collected <a href="#types_of_data" id="types_of_data"></a>

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; launches; operating systems; Universally unique identifier (UUID); crash data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.\
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.\
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.\
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.\
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

### Mode and place of processing the Data <a href="#place_of_processing" id="place_of_processing"></a>

#### Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

#### Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

#### Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

### The purposes of processing <a href="#use_collected_data" id="use_collected_data"></a>

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Advertising, Platform services and hosting, Content performance and features testing (A/B testing) and Infrastructure monitoring.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

### Detailed information on the processing of Personal Data <a href="#data_processing_detailed_info" id="data_processing_detailed_info"></a>

Personal Data is collected for the following purposes and using the following services:

#### Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.\
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.\
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.\
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

* **Unity Ads (Unity Technologies ApS)**
  * Unity Ads is an advertising service provided by Unity Technologies ApS.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Denmark – [Privacy Policy](https://unity3d.com/legal/privacy-policy).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **AdMob**
  * AdMob is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.\
    **In order to understand Google's use of Data, consult** [**Google's partner policy**](https://policies.google.com/technologies/partner-sites).

    Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

    Place of processing: United States – [Privacy Policy](https://www.google.com/policies/technologies/ads/) – [Opt Out](https://adssettings.google.com/authenticated); Ireland – [Privacy Policy](https://www.google.com/policies/technologies/ads/).

    Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **ironSource (ironSource Ltd.)**
  * ironSource is an advertising service provided by ironSource Ltd.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Israel – [Privacy Policy](http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **InMobi (InMobi Pte Ltd)**
  * InMobi is an advertising service provided by InMobi Pte Ltd.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: India – [Privacy Policy](https://www.inmobi.com/privacy-policy-for-eea) – [Opt out](https://www.inmobi.com/page/opt-out/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **Fyber (Fyber N.V)**
  * Fyber is an advertising service provided by Fyber N.V.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Germany – [Privacy Policy](https://www.fyber.com/legal/privacy-policy/) – [Opt out](https://www.fyber.com/privacy-policy/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **Pangle (BYTEDANCE PTE. LTD.)**
  * Pangle is an advertising service provided by BYTEDANCE PTE. LTD.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Singapore – [Privacy Policy](https://www.pangleglobal.com/privacy) – [Opt out](https://www.pangleglobal.com/privacy/enduser-en).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **PubMatic (PubMatic, Inc.)**
  * PubMatic is an advertising service provided by PubMatic, Inc.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – [Privacy Policy](https://pubmatic.com/legal/privacy/) – [Opt Out](https://pubmatic.com/legal/opt-out/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **Smaato (Smaato, Inc.)**
  * Smaato is an advertising service provided by Smaato, Inc.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – [Privacy Policy](https://www.smaato.com/privacy/) – [Opt out](https://www.smaato.com/privacy/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **Mintegral (Mintegral international limited)**
  * Mintegral is an advertising service provided by Mintegral international limited.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: China – [Privacy Policy](https://www.mintegral.com/en/privacy/) – [Opt out](https://www.mintegral.com/en/privacy/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **AppLovin (AppLovin Corporation)**
  * AppLovin is an advertising service provided by AppLovin Corporation.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – [Privacy Policy](https://www.applovin.com/privacy/) – [Opt out](https://www.applovin.com/privacy/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **Chartboost (Chartboost, Inc.)**
  * Chartboost is an advertising service provided by Chartboost Inc.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – [Privacy Policy](https://help.chartboost.com/legal/privacy).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California
    * a Sharing in California

* **Google Ad Manager (Google LLC)**

  * Google Ad Manager is an advertising service provided by Google LLC that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered. &#x20;

    &#x20;

    Users may decide to disable all the DoubleClick Cookies by going to: [Google Ad Settings](https://adssettings.google.com/authenticated?hl=en).

    &#x20;

    In order to understand Google's use of Data, consult their [partner policy](https://policies.google.com/technologies/partner-sites) and their [Business Data page](https://business.safety.google/privacy/).

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – [Privacy Policy](https://business.safety.google/privacy/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

* **BidMachine (Appodeal, Inc.,)**

  * BidMachine is an advertising service provided by Appodeal, Inc..

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – [Privacy Policy](https://bidmachine.io/privacy-policy/) – [Opt out](https://explorestack.com/privacy-policy/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

* **VERVE (Verve Group Europe GmbH)**
  * VERVE is an advertising service provided by Verve Group Europe GmbH.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Germany – [Privacy Policy](https://pubnative.net/privacy-notice/) – [Opt out](http://bw6shc.myraidbox.de/privacy-notice/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

#### 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**
  * Firebase Remote Config is an A/B testing and configuration service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – [Privacy Policy](https://www.google.com/policies/privacy/); Ireland – [Privacy Policy](https://policies.google.com/privacy).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California

#### 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. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

* **Google Play Store**

  * This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

    &#x20;

    By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

    &#x20;

    Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on [this page](https://support.google.com/accounts/answer/6078260).

    Personal Data processed: Usage Data.

    Place of processing: United States – [Privacy Policy](https://policies.google.com/privacy); Ireland – [Privacy Policy](https://policies.google.com/privacy).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

* **Apple App Store (Apple Inc.)**
  * This Application is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

    &#x20;

    By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of this Application. Much of this information is processed on an opt-in basis.

    &#x20;

    Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on [this page](https://support.apple.com/en-us/HT202100).

    Personal Data processed: Usage Data.

    Place of processing: United States – [Privacy Policy](https://www.apple.com/legal/privacy/).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

#### 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 (Unity Technologies ApS)**
  * Unity Analytics is an analytics service provided by Unity Technologies ApS.

    Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

    Place of processing: Denmark – [Privacy Policy](https://unity3d.com/legal/privacy-policy).

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    * a Sale in California

* **Google Analytics for Firebase**
  * Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.\
    **In order to understand Google's use of Data, consult** [**Google's partner policy**](https://www.google.com/policies/privacy/partners/).

    &#x20;

    Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

    &#x20;

    This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

    &#x20;

    Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

    Personal Data processed: Application opens; Application updates; device information; geography/region; In-app purchases; launches; number of sessions; number of Users ; operating systems; session duration; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

    Place of processing: United States – [Privacy Policy](https://policies.google.com/privacy); Ireland – [Privacy Policy](https://policies.google.com/privacy).

    Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; geolocation data.

    This processing constitutes:

    * a Sale in California

#### 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. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

* **Crashlytics (Google Ireland Limited)**
  * Crashlytics is a monitoring service provided by Google Ireland Limited.

    Personal Data processed: crash data; device information; Universally unique identifier (UUID).

    Place of processing: Ireland – [Privacy Policy](https://policies.google.com/privacy).

    Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

    This processing constitutes:

### Information on opting out of interest-based advertising <a href="#opt_out" id="opt_out"></a>

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](http://www.youronlinechoices.com/) (EU), the [Network Advertising Initiative](https://thenai.org/about-online-advertising/) (US) and the [Digital Advertising Alliance](https://www.aboutads.info/consumers/) (US), [DAAC](http://youradchoices.ca/understanding-online-advertising) (Canada), [DDAI](http://www.ddai.info/optout) (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called [AppChoices](https://youradchoices.com/appchoices) that helps Users to control interest-based advertising on mobile apps.

Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

### Further Information for Users <a href="#cookie_policy_further_information" id="cookie_policy_further_information"></a>

#### 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.

#### Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

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. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.\
\
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.

#### The rights of Users based on the General Data Protection Regulation (GDPR) <a href="#rights_subjects" id="rights_subjects"></a>

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.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

#### **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.**

**Users must know that, 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. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.**

#### **How to exercise these rights**

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

### Further information for Users in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).\
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.\
This part of the document uses the term “personal information“ as it is defined in the **LGPD**.

#### The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

* your consent to the relevant processing activities;
* compliance with a legal or regulatory obligation that lies with us;
* the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
* studies conducted by research entities, preferably carried out on anonymized personal information;
* the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
* the exercising of our rights in judicial, administrative or arbitration procedures;
* protection or physical safety of yourself or a third party;
* the protection of health – in procedures carried out by health entities or professionals;
* our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
* credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

#### Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

#### Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

#### Your Brazilian privacy rights, how to file a request and our response to your requests

**Your Brazilian privacy rights**

You have the right to:

* obtain confirmation of the existence of processing activities on your personal information;
* access to your personal information;
* have incomplete, inaccurate or outdated personal information rectified;
* obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
* obtain information on the possibility to provide or deny your consent and the consequences thereof;
* obtain information about the third parties with whom we share your personal information;
* obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
* obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
* revoke your consent at any time;
* lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
* oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
* request clear and adequate information regarding the criteria and procedures used for an automated decision; and
* request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

**How to file your request**

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

**How and when we will respond to your request**

We will strive to promptly respond to your requests.\
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an **access** or personal information **processing confirmation** request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.\
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.\
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a **rectification, deletion, anonymization or personal information blocking** request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.

#### Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

* when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
* when the transfer is necessary to protect your life or physical security or those of a third party;
* when the transfer is authorized by the ANPD;
* when the transfer results from a commitment undertaken in an international cooperation agreement;
* when the transfer is necessary for the execution of a public policy or legal attribution of public service;
* when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

### Further information for Users in the United States <a href="#all_us_laws_info" id="all_us_laws_info"></a>

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information.

#### Notice at collection <a href="#notice_at_collection" id="notice_at_collection"></a>

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

*While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.*

* Internet or other electronic network activity information

  * Personal Information collected or disclosed:
    * various types of Data as specified in the privacy policy of the service, Usage Data, Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), device information, geography/region, number of Users , number of sessions, session duration, In-app purchases, Application opens, Application updates, launches, operating systems, Universally unique identifier (UUID), crash data, Trackers
  * Purposes:
    * Analytics
    * Advertising
    * Platform services and hosting
    * Content performance and features testing (A/B testing)
    * Infrastructure monitoring
  * Retention period:
    * for the time necessary to fulfill the purpose
  * Sold or Shared ℹ️: Yes
  * Targeted Advertising: ℹ️: Yes
  * Third-parties: Unity Technologies ApS, Google LLC, Apple Inc., ironSource Ltd., Meta Platforms, Inc., Google Ireland Limited, InMobi Pte Ltd, Fyber N.V, BYTEDANCE PTE. LTD., PubMatic, Inc., Smaato, Inc., Mintegral international limited, AppLovin Corporation, Chartboost, Inc., Appodeal, Inc.,, Verve Group Europe GmbH

* Commercial information

  * Personal Information collected or disclosed:
    * Tracker, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), device information, geography/region, number of Users , number of sessions, session duration, In-app purchases, Application opens, Application updates, launches, operating systems
  * Purposes:
    * Analytics
  * Retention period:
    * for the time necessary to fulfill the purpose
  * Sold or Shared ℹ️: Yes
  * Targeted Advertising: ℹ️: Yes
  * Third-parties: Google LLC

* Identifiers

  * Personal Information collected or disclosed:
    * Tracker, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), device information, geography/region, number of Users , number of sessions, session duration, In-app purchases, Application opens, Application updates, launches, operating systems, Universally unique identifier (UUID), crash data
  * Purposes:
    * Advertising
    * Analytics
    * Infrastructure monitoring
  * Retention period:
    * for the time necessary to fulfill the purpose
  * Sold or Shared ℹ️: Yes
  * Targeted Advertising: ℹ️: Yes
  * Third-parties: Google LLC, Meta Platforms, Inc., Google Ireland Limited

* Geolocation data
  * Personal Information collected or disclosed:
    * Tracker, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), device information, geography/region, number of Users , number of sessions, session duration, In-app purchases, Application opens, Application updates, launches, operating systems
  * Purposes:
    * Analytics
  * Retention period:
    * for the time necessary to fulfill the purpose
  * Sold or Shared ℹ️: Yes
  * Targeted Advertising: ℹ️: Yes
  * Third-parties: Google LLC

ℹ️ You can read the definitions of these concepts inside the “[Definitions and legal references section](https://www.iubenda.com/privacy-policy/96847333#definitions_and_legal_references)” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities you can refer to the “[Your privacy rights under US state laws](https://www.iubenda.com/privacy-policy/96847333#privacy_rights_under_us_state_laws)” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “[Detailed information on the processing of Personal Data](https://www.iubenda.com/privacy-policy/96847333#data_processing_detailed_info)” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

#### What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

#### Your privacy rights under US state laws <a href="#privacy_rights_under_us_state_laws" id="privacy_rights_under_us_state_laws"></a>

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

* the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
* the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
* the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
* the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
* the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
* the right to non-discrimination.

**Additional rights for Users residing in California**

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

* The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
* The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

**Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana**

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have

* The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
* The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

**Additional rights for users residing in Utah and Iowa**

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have

* The right to opt out of the processing of your Personal Information for Targeted Advertising;
* The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

#### How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

**How to exercise your rights to opt out**

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“[GPC](https://globalprivacycontrol.org/)”), you are free to do so and we will abide by such request in a frictionless manner.

**How and when we are expected to handle your request**

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

### Additional information about Data collection and processing <a href="#further_data_processing_info" id="further_data_processing_info"></a>

#### Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

#### Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

#### System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

#### Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

#### Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.\
\
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

#### Definitions and legal references

**Personal Data (or Data) / Personal Information (or Information)**

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

**Sensitive Personal Information**

Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.

**Usage Data**

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

**User**

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

**Data Subject**

The natural person to whom the Personal Data refers.

**Data Processor (or Processor)**

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

**Data Controller (or Owner)**

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

**This Application**

The means by which the Personal Data of the User is collected and processed.

**Service**

The service provided by this Application as described in the relative terms (if available) and on this site/application.

**Sale**

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.

**Sharing**

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.

**Targeted advertising**

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.

**European Union (or EU)**

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

**Cookie**

Cookies are Trackers consisting of small sets of data stored in the User's browser.

**Tracker**

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

***

**Legal information**

This privacy statement has been prepared based on provisions of multiple legislations.

This privacy policy relates solely to this Application, if not stated otherwise within this document.

### CHANGES TO THIS POLICY <a href="#changes-to-this-policy" id="changes-to-this-policy"></a>

We will update this policy to reflect changes in our practices and services, and take appropriate measures to notify you of any significant changes in accordance with applicable data protection laws. When we post changes to this policy, we will revise the "Last Updated" date at the top of this policy.
