PRIVACY POLICY - KEEN EDGE TECH LIMITED

Introduction

KEEN EDGE TECH LIMITED respects the privacy of the visitors to our digital properties and the users of our products, and we are committed to protecting it through our compliance with this Privacy Policy (“Policy”). This Policy explains how KEEN EDGE TECH LIMITED and its subsidiaries and affiliated companies ( “we,” “our” or “us”) collect, use, and share your personal information when you access or use our websites, our mobile applications (“Apps”), or any associated features, content, or pages owned or operated by us (collectively, “Services”) that link to this Policy. This Policy does not address the privacy practices of any third parties that we do not own or control.

We may modify this Privacy Policy from time to time. We will notify you of material changes to this Policy by posting the new version on the Services before the effective date of the changes. If you do not agree with the proposed changes, you should discontinue your use of the Services prior to the time the new Policy takes effect. If you continue using the Services after the new terms take effect, you understand and acknowledge that the modified Privacy Policy will apply.

PERSONAL INFORMATION WE COLLECT

We will process and use the following Information about you:

• Information you provide to us

• Registration information:

• Website: if you register to play a Game on the Website, you will be asked to create an account where you share your e-mail and username. When you register using a third party like Google or Facebook, we will know if you have a valid account with such third party, but we will not have access to your login details.

• Information you provide when using the Games: when you play the Games, we may ask you to choose a username.
• In-Game Communication: in some Games you can interact with other players via chat. In this case we would process Information regarding such interactions, including timestamps or chat content. In some cases, these functionalities may be provided by third parties, in which case we may not have access to the content of such communications.

• Information we automatically collect or is generated about you when you play the Games

• Identifiers: your IP address, advertising ID, Singular  ID, HTTP header, MAC address, device ID, third-party app IDs (apptoken), unique  ID, country and city level location data and device information (such as model, brand, language, and operating system).
• Cookies: we use cookies and other similar technologies (e.g., web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience when using the Games. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit installation of such Cookies or subsequently disable them. You may accept all Cookies or instruct the device or web browser to provide notice at the time of installation of Cookies or refuse to accept all Cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install Cookies, the Game may be unable to operate as designed.
• Information regarding your use of the Games: game ID, install and uninstall timestamps. date and time stamps of game events, game time, achieved scores, interactions with our teams, advertising and promotions engagement, transaction records, evidence of you using cheating software or using modified versions of the Games.

• Information received from third parties

• Registration via third parties: when you register using a third-party account (e.g. Facebook, Google or Apple) we receive your name, profile picture, third party ID, email address (optional) and friends list (optional).
• Payment providers: When you make payments in our Games, we receive the following Information from our payment providers about your transactions: transaction ID, country, payment provider used, purchased item, currency, value, and payment timestamp.
• Analytics Information: we integrate analytics software from third party analytics providers in some of our Games. We then receive reports that help us optimise our in-game features and events to each user of our Games which include your user ID and information on your in-game activity.
• Advertising partners: we receive Information from third-party advertising providers, including user ID and Information on your interactions with advertising shown in on our Mobile Games.
• Mobile measurement partners: we receive information from third parties to allow us to track performance of our marketing campaigns and to detect fraud in such campaigns. This includes advertising ID, IP address, location, and transaction information.
• Communication providers: in some Games you may have functionalities like chat. When these are provided by third parties, we will receive Information about you from them, including third-party IDs, usernames, or content in some cases.

HOW WE USE YOUR PERSONAL INFORMATION

We use your Information to:

• Provide you with the Games. We will use your Information to perform our contractual obligation towards you to allow you to create an account, play the Games (including as a guest), remember your progress, allow you to play Games with your friends and communicate with them via in-Game (if applicable). We will also use your Information to allow you to make purchases via Google Play, IOS App Store, Facebook and other Payment service Providers, and maintain a record of such purchases. The Information we process when doing so includes your registration Information, Information you provide to us when playing the Games, identifiers, Information you generate and display when playing the Games, and Information regarding your use of the Games.
• Improve and monitor Game use. It is in our legitimate interests to improve our Games for our customers. When doing so, we may automatically collect information or generate Information about you when you play the Games, as well as Information about your device such as battery, Wi-Fi strength, device manufacturer, model and operating system, and the amount of free space on your device.
• Provide you with support and to respond to your requests or complaints. If you reach out to us for support, we will use your Information to create a support account for you, respond and resolve your queries and complaints, facilitate support (e.g., retrieval of a forgotten password). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your registration Information, your identifiers, information about your device such as your Wi-Fi strength and the amount of free space on your device, and any other Information about you collected via our customer support channels.
• Conduct analytics. It is in our legitimate interests to analyse the use of and inform, our Games, newsletters and advertising campaigns, and any other interaction or interest in the same. When doing so we will process Information we automatically collect or is generated about you when you play the Games or interact with our newsletters and advertising campaigns to (a) create anonymised and aggregated data; (b) create segments of users who show particular characteristics or interests; and (c) conduct predictive analytics about your interests.
• Send you updates about in-Game offers. We will show you promotional offers and information about virtual items that can be purchased in-game, which will be tailored to you based on gameplay, geography, device data and in-game interactions. We do this based on our legitimate interest.
• Provide you with advertising. We will present you with ads and suggestions in our Games and elsewhere. These may be ads relating to our own Games or other services you may be interested in. These ads and suggestions may be tailored specifically to you. Where it is required, we will only do so where we have your consent. In situations where your consent is not required, or where we provide contextual advertising, we do so based on our legitimate interests. If you no longer want to receive targeted advertising you can withdraw your consent in the Games settings, or if that option is not available, please see our Privacy Policy which explains how you can opt out and change your browser and device settings. To tailor ads and to allow our advertising partners to tailor ads, we process Information we automatically collect or is generated about you when you play the Games and Information received from third parties.
• Prevent fraud, defend against legal claims or disputes, enforce our terms and to comply with our legal obligations. It is in our legitimate interests to protect our users against online abuse and other anti-social or illegal activity (e.g., when moderating conversation in our Games). Furthermore, it is also in our legitimate interest to protect our interests by (1) monitoring Game use to detect fraud or any other user behaviour which prejudices the integrity of our Games, (2) taking steps to remedy fraud and concerning behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our terms and policies. When doing so, we will process the Information relevant in such a case, including Information you provide us, Information we automatically collect about you, and Information which is provided to us by third parties.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share your Information with selected third parties, including:

• Other players and users will see your profile Information and in-game activities, as well as any other Information you choose to share with them, such as chat data;
• Vendors and service providers we rely on for the provision of the Games, for example:

• Cloud service providers who rely on for data storage, including Hetzner who are based in Germany;
• Customer support solution providers, who help us manage and respond to our customer questions and complaints. This includes Zendesk Inc., who are based in the U.S. and who host our customer support function;
• Analytics providers: we work with a number of analytics, segmentation and mobile measurement service providers who help us understand our userbase. This includes Singular Inc., who are based in the United States;
• Social media. We integrate certain Facebook, Apple Sign In and Google software to enhance social media features in the game such as accessing your friends list and displaying your profile picture; and
• User acquisition. We work with a variety of user acquisition partners to help us report on the success of our marketing campaigns. We may use some of your Information to participate in Custom Audience and Lookalike Audience programmes, which enable us to display adverts to both existing and prospective supporters when they visit one of our partners’ websites. We may provide an identifier (i.e. your Advertising ID or Facebook ID) to them so they can determine whether you are a registered account holder with them. Our adverts may then appear when you access their websites. See our list of partners.

• Advertising partners. We are an ad-supported service. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads in our Games, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, personalise advertising, or similar activities. See our list of partners. For more information on how to limit or opt-out from personalized advertisement, please see our Privacy Policy.
• Payment processors: For Mobile Games and Facebook Games, we use payment processors such as Google (if you run Android on your mobile device), Apple App Store payments (if you run IOS on your mobile device) and Facebook (if you make a payment in a Facebook Game). To process payments on the Website, we rely on Stripe, Boku, Hipay, Paypal, PaySafeCard. These payment processors are responsible for the processing of your Information, and may use your Information for their own purposes in accordance with their privacy policies as below:

• Companies who belong to the same group as . We share your Information with different entities which are part of our group of companies.
• Law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).
• Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

Company Name	Brief Introduction	Privacy Policy
AppLovin	AppLovin is an advertising service provided by AppLovin Corporation. (US)	https://www.applovin.com/privacy
Chartboost	Chartboost is an advertising service provided by Chartboost, Inc. (US)	https://answers.chartboost.com/en-us/articles/200780269
Facebook Audience Network	Facebook Audience Network is an advertising service provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services and targeted ads. Facebook does not require opt-in or opt-out signals from users in our services. Relevant signals are collected directly from the user upon creating an account in such Services.	https://www.facebook.com/about/privacy/
Fyber	Fyber is an advertising service provided by Fyber Group. (Israel)	https://www.fyber.com/legal/privacy-policy/
Display.io	Display.io is an advertising service provided by Display.io. INC (US)	https://www.display.io/privacypolicy/
Google AdMob and their partners	AdMob by Google is provided by Google Inc. (US)	http://www.google.com/policies/privacy/ For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903 You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
Google AdSense	Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.	You may opt-out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
IronSource	IronSource is an advertising service provided by IronSource, Inc. (US) and does not require opt-in or opt-out signals from users in our Services, since they provide only non-personalized ads in our Services.	http://www.ironsrc.com/wp-content/uploads/2017/01/ironSource-Privacy-Policy.pdf
MoPub and their partners	MoPub is provided by MoPub, Inc. (US)	http://www.mopub.com/legal/privacy/ For more information on MoPub Partners, please visit: https://www.mopub.com/legal/partners/ You can opt-out from MoPub service by following the instructions on MoPub Opt-out page: http://www.mopub.com/optout/
Smaato and their vendors	Smaato is an advertising service provided by Smaato, Inc. (US)	https://www.smaato.com/privacy/ For more information on the Smaato Vendors, please visit: https://www.smaato.com/partner-list/
Unity Ads	Unity Ads is an advertising service provided by Unity Ads Inc. (US)	https://unity3d.com/legal/privacy-policy
Vungle	Vungle is provided by Vungle, Inc. (US)	http://vungle.com/privacy/
Mintegral	Mintegral is provided by Mintegral International Limited(China)	https://www.mintegral.com/en/privacy/
Pangle	Pangle is provided by ByteDance Pte. Ltd. (Singapore)	https://ad.oceanengine.com/union/media/privacy
Yandex	Yandex is provided by Yandex Europe AG (Russia)	https://yandex.com/legal/confidential/
Pubmatic	Pubmatic is provided by Pubmatic, Inc (US)	https://pubmatic.com/legal/privacy-policy/
Amazon	Amazon is provided by Amazon.com, Inc. (US)	https://www.amazon.com/gp/help/customer/display.html?nodeId=468496
BidMachine	BidMachine is provided by BidMachine, Inc. (US)	https://bidmachine.io/privacy-policy/
MyTarget	MyTarget is provided by My.com B.V. (Netherlands)	https://legal.my.com/us/mytarget/privacy/
A4G	A4G is an advertising service by Ad4Game Ireland Limited	https://www.a4g.com/privacy
InMobi	InMobi is an advertising service provided by InMobi PTE Ltd (Singapore)	https://www.inmobi.com/privacy-policy/
Yahoo and partners	Yahoo, previously known as Verizon Media/Oath, is  an advertising service provided by Yahoo Ad Tech LLC (USA)	https://legal.yahoo.com/us/en/yahoo/privacy/index.html For more information on Yahoo partners, please visit: https://legal.yahoo.com/ie/en/yahoo/privacy/topic/ourpartners/index.html
ReklamUp	ReklamUp is an advertising service provided by Arsus Technologies Ltd (TURKEY)	https://reklamup.com/privacy.php
AWS	AWS is a cloud computing service provided by Amazon Web Services, Inc. (US).	https://aws.amazon.com/privacy/
Facebook Analytics	Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services.	https://www.facebook.com/about/privacy/
Firebase	Firebase is an analytics service provided by Google Inc. (US). You may opt-out of certain Firebase features through your mobile device settings.	http://www.google.com/intl/en/policies/privacy/
Google Analytics	Google Analytics is an analytics service provided by Google Inc. (US)	https://policies.google.com/privacy
Singular	Singular Analytics is an analytics service provided by singular	https://www.singular.net/privacy-policy/

How Do We Share, Reveal or Transfer Your Personal Information?

When sharing, transferring, and revealing your personal information, we stick to three principles, minimum, necessary, and legal. Under no normal circumstances will we share, transfer, sell or reveal your personal information to outsiders. But, within the confines of applicable laws and regulations, we might share, transfer and reveal your personal information under the following circumstances:

ü We will reveal it to consultants, law enforcement agencies, and judicial and regulatory authorities to protect the legal rights and interests of you or other users or other individuals' lives, property, and other legal rights within the confines of laws and regulations.

ü We are under a legal obligation or this is a mandatory requirement from relevant departments.

ü When you obtain virtual products related to our products via purchasing, the transaction will take place via a third party payment service provider. You will then inevitably disclose to this provider or a potential transaction provider your information, including contact information, bank account, or email address. Please protect your information by providing it to others only when it is necessary.

ü When structural changes, including M&A and reorganization, take place, we may need to transfer your personal information to the third parties who acquire or inherit part or all our assets or stocks. If the changed entity needs to change the purpose of using your personal information, we will require it to solicit your explicit consent first.

ü If we discover that you are utilizing our applications, services, and their related information for fraud or illegal activities, we will take suitable measures which include but are not limited to suspending or terminating your access to our application or services.

How Do We Store and Protect Your Personal Information?

How do we store your personal information?

In order to protect your personal information, the information that we collect will be stored according to relevant privacy laws and regulations in related countries. We will also store collected personal information inside or outside of the country or region where we operate within the permitted confines of local laws and regulations.

If we cease to provide services or operate, we and the third parties we cooperate with will stop collecting your personal information in time and shall abide by relevant laws and regulations to inform you in advance and delete or anonymize your personal data after we cease to operate or provide services unless there are laws, regulations or regulatory authority that demand otherwise.

How do we protect your personal information?

Security Safeguards

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures, such as limitation of access to personal information by personnel, utilizing Firewalls encryption, backup systems, bastion host to access cluster, RBAC to manage cluster resources, to protect your data from unauthorized access or against loss, misuse or alteration.

Although we use commercially reasonable efforts to assure that your data remains secure when maintained by us, please, be aware that no security measures are perfect or impenetrable.

Data retention

We keep your information only so long as we need it to provide our Services to you and fulfill the purposes described in this Privacy Policy. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either destroy it or depersonalize it so that we cannot identify you.

The procedure and method of destroying the information is as follows:

Destroying Procedure: Your personal information will be destroyed without delay after the end of retention period or after its purpose has been achieved.

Destroying Method: Printed personal information will be shredded through a paper shredder. If the information is stored as a data file, it will be deleted safely in an irreversible way.

How Do We Manage Your Personal Information?

Access, update, and deletion of personal information

We think very highly of your right to manage your personal information. But if you choose to delete this information, certain features that require this kind of information to function may become unavailable. Please contact us if you wish to check, edit or delete your personal profile. We will take reasonable measures after your identity is verified and your specific requirements are made clear.

European Data Protection Rights

If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

-You can request access to, and rectification or erasure of, personal data;

-If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;

-If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;

-You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances;and

-For residents of France, you can send us specific instructions regarding the use of your data after your death.

When we are processing data on behalf of another party that is the "data controller," you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.

How Do We Process Personal Information?

ü According to relevant laws and regulations, minors under the age of 16 should read this privacy policy in the company of parents or legal guardians. Under no circumstances are minors allowed to use our services without parents' or legal guardians' consent to this privacy policy. Please contact us if you have questions.

ü Please be reminded that we will not intentionally collect or solicit personal data about minors under the age of 16, or direct them to interest-based advertisements, or intentionally allow such people to use our services. If you are a minor under the age of 16, please do not send us any personal data about you, including your name, address, phone number, or email address. Minors under the age of 16 cannot provide any personal data. If we learn that we have collected any personal data about minors under the age of 16, we will apply every reasonable method to delete that data. Please contact us if you believe that we might have data from or related to minors under the age of 16.

ü Please be reminded that the definition of a minor varies in different nations. In order to make sure that minors' information is properly and safely protected, we have set the age limit at 16 according to laws and regulations in relevant nations. Please contact us if you have questions.

Cookies and similar technologies

Cookies are small data files, typically of letters and numbers, that are placed by a web server on your device. We and companies we work with may use cookies and similar technologies, including pixel tags, web beacons, mobile analytics features, and mobile identifiers (collectively, “tracking technologies”) to collect information for many reasons, such as to keep you logged in to your account, remember your preferences and settings, analyze usage of our Services, measure the performance of our Services and advertising campaigns, and ensure security on our Services. Some of the functions performed by tracking technologies are strictly necessary for us to be able to offer you our Services, while others provide us with valuable insight about how we can improve or market our Services.

Security

We take the security of your personal information very seriously. We strive to adopt reasonable measures designed to protect your personal information from unauthorized access, disclosure, use, alteration, and corruption or loss. We shall take reasonable measures to protect your personal information and to ensure the accuracy and timely update of the personal information collected about you.

Please understand that due to the nature of the internet industry, it is impossible to ensure that systems are 100% secure. You should understand that the systems may encounter issues due to the factors beyond our control, such as malicious actors. We also depend on you to keep your account information and other personal information secure by keeping your password confidential and taking precautions to keep others from accessing your account. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically (e.g., via email we have on file for you or via a posting on our website or digital properties), in writing, or by telephone, if required or permitted to do so by law.

Children

Our Services are not intended for use by children under the age of sixteen (16). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent. If you are under the age of sixteen (16), please do not provide us with information of any kind whatsoever. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received information from a child under the age of sixteen (16), please contact us immediately according at wangsy@keen-edge-tech-limited.com.

US Privacy Rights

This section provides additional information for residents of California, Virginia, Colorado, Utah, and Connecticut, Texas and Oregon.

If you are a resident of California, Virginia, Colorado, Utah or Connecticut, you have certain privacy rights as specified under your state law: California Consumer Privacy Act of 2018 (“CCPA”), the Virginia Consumer Data Protection Act (“CDPA”), the Colorado Privacy Act (“CPA”), the Utah Consumer Privacy Act (“UCPA”), the Connecticut Data Privacy Act (“CTDPA”), Texas Data Privacy and Security Act (TDPSA), Oregon Consumer Privacy Act (OCPA) (together “US Privacy laws”).

This section describes how to exercise those rights and our process of handling those requests. We reserve the right to ask for reasonable information to verify your identity before we process your request.

The easiest way to submit a request is to use the in-app support feature (“Contact Us”) in our games. You may also submit your request via e-mail at wangsy@keen-edge-tech-limited.com

Please, note that your request must:

• provide sufficient information necessary to verify you as our user about whom we collected and processed personal data or to verify you as an authorized representative of such a user;
• contain sufficient details describing your request to allow us to properly understand, review and respond to it;

We will respond to your request within 45 days, and in more difficult cases we may extend our response time by another 45 days. We reserve the right not to respond to your request or provide you with personal data, in case we were unable to verify your identity or authority to make such a request.

Contact us

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, you can contact us at wangsy@keen-edge-tech-limited.com