Privacy Policy

I. Important Definitions

• "Personal Data" means any information that relates to a living individual directly or indirectly and can be used to identify a living individual, in particular by reference to an identifier, location, or factors specific to the physical, physiological, genetic, economic, cultural or social identity.
• "Usage Data" means data collected automatically either generated by the use of the Service or from the Service infrastructure itself.
• "Cookies" are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience and see which areas and features of our Services are popular and count visits.
• "Data Controller" means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data is, or will be, processed. For the purpose of this Policy, we are a Data Controller of your data.
• "Data Subject" is any living individual who is the subject of Personal Data.

II. Data We Collect and Use

1. Overviews

For your better experience in our Services, we may require you to provide us with certain Personal Data while using our Services. We may collect your Personal Data in the following ways:

• Information you directly provide to us (such as your nickname, profile picture and phone number you provide to us when you register or login to your account);
• Information we obtain automatically during your use of our Services (such as Device Information and Usage Data);
• Information we obtain from other sources.

We will collect and use your Personal Data only for the purposes described in this Policy.

2. Data Collection and Purposes

We may collect some or all of the following information about you when you use our Services for legitimate interests.

(1) Login Information

If you sign up with your e-mail/mobile phone number when you create an account in our Games, you consent to provide some of your Personal Data, such as e-mail address, verification code by email or SMS, and password.

If you register via social network accounts, such as Apple ID, Facebook or Google Play ("Social Networks"), we may collect information you authorized the Social Networks to share with us to sign up for our Services. Exactly what information we receive from the Social Networks may vary due to your privacy settings on such Social Network, but it would typically include your basic public profile information such as your nickname, username and profile picture. If you refuse to provide information of your Social Networks accounts, you may not have the option to register and log in by your Social Networks accounts.

For certain regions, you may be asked to provide us with your date of birth to verify that you are eligible to access or use our Services.

(2) Account Information

When you use our Services, you have choices about the information you provide on your Account, such as your profile picture, nickname, gender, date of birth and location. You don't have to provide additional information on your profile; however, profile information helps you to get more from our Services, including making others to better know you. Please do not post or add additional information to your profile that you would not want to be publicly available.

(3) Payment Information

When you purchase virtual currency or virtual items in our Services, we may collect and process your purchase and transaction record in the Services, including device information (including Open ID, Internet Protocol (IP) address, OS version, type of device, internet connection), transaction details (time and date, cost, product purchased, currency, order ID) and transaction records (including player ID, time of transaction, country, email, phone number, purchase history and payment card details), to perform our contract with you to facilitate your payment and provide you with details of your transactions.

All purchases and withdrawals are processed by payment processing companies. We do not process the payments for any payment nor do we have any access to your credit card information or billing information.

(4) Any Information You Submit to Our Support Team

If you encounter any problems while using our Services, you may contact us and seek assistance through our technical and/or customer service. In case of receiving your request for support, we may collect the content of your enquiry, your device information, contact details or other contact information you leave with us in order to contact you or help you resolve the problem, or to record the problem and its solution. If you choose not to provide such information, we may not be able to provide you with this service, but your use of other features of our Services will not be affected.

(5) Advertising Information

We may store the ad identification number for the advertisement, such as Android ADID and Apple IDFA information and device information with your profile to track the success of our advertising if you click on advertisements in our Services.

In order to provide you with personalized advertisements, promotional activities and marketing communications, subject to your election and consent, we may collect and process the following information, such as age, gender, e-mail address, geographical location, device type, in-game information (such as your habits and preferences in our Games) and other information you choose to provide to us in any surveys or inquiries.

We may also use the information you provide to send you deliver advertisements, market surveys or research by email. If you don't want to receive such messages from us, you may opt-out of receiving such messages (see "Promotional Communications" below).

Please note that when you opt out of receiving interest-based or targeted advertising, you will still see advertisements from us or on our online services, but that advertising will not be targeted using your Personal Data. If we know that you are a registered user under the legal age of majority in accordance with the applicable laws of some jurisdictions from which you access or use our Services, we will not target you with advertising or send you such messages.

(6) Data We Automatically Collect

During your use of our services, in order to improve our services and ensure the security of our services, we will automatically collect information about your devices or your usage of our Services, including:

• Internet Protocol (IP) address: We collect and process this information to allow you to access or restrict your access to our Services.
• Device information: When you start using our Services, based on your specific actions in our Services and the specific permissions you have granted to us during the installation and use of our Services, we will collect information about the mobile device you are using to ensure service security, manage registrations and improve our Services, such as UUID, IMEI, MAC address, IDFA, your device model, operating system and version, APK name, App version, device display resolution, device setting, CPU information, storage information, battery usage status, time zone settings and device location information (Internet Protocol (IP) address, GPS location and WLAN connection, Bluetooth and cell site information that provides location information).
• Usage Data: For the purposes of performing our Terms of Service, we will collect details of your use of our services and keep them as Usage Data when you use our services, including your login account, IP address, provider information, internet connection environment, WIFI status information, and other Usage Data generated when you use our Services.

Please note that some of the above-mentioned information alone cannot be used to identify a specific natural person, thus cannot be considered as Personal Data. Only when such non-Personal Data is used in combination with other information to identify a specific natural person, or when it is used in combination with Personal Data, will this information be regarded as Personal Data during such combination. In this case, we will anonymize and de-identify this type of information, unless with your consent or otherwise according to laws and regulations. The above-mentioned information is essential as to the provision of the Service. If you choose not to provide them, we may not be able to provide you with our Services.

(7) Survey Information

We may also collect other information about you that we reasonably need to improve our products or services, including any feedback you provide when you contact customer service and any questionnaire you send back to us when you participate in a survey. We may combine information from one service with information from others in order to provide you with better service.

(8) Other Situations in Which Your Information May Be Collected

To the extent permitted by law, we may obtain your Personal Data from other individuals, business entities, public sources or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.

We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection prior to obtaining your consent.

III. Promotional Communications

We may use your Personal Data to send you updates about our Services, including exclusive offers, promotions, or new services. We have a legitimate interest in processing your Personal Data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your Personal Data with the utmost respect and never sell it to other organizations for marketing purposes.

You have the right to opt-out of receiving promotional communications at any time by:

• Contacting us (see "How to Contact Us" below); or
• Using the "unsubscribe" link in emails or "STOP" number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, applicable regulations, or structure of our business.

IV. How and Why We Use Your Personal Data

Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:

• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests.

We may use your Personal Data for:

• Providing Services to you for the performance of our contract with you or to take steps at your request before entering into a contract;
• Preventing and detecting fraud against you for our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you;
• Conducting checks to identify our customers and verify their indent to comply with our legal and regulatory obligations;
• Ensuring the confidentiality of commercially sensitive information for our legitimate interests or those of a third party;
• Statistical analysis to help us manage our business;
• Preventing unauthorized access and modifications to systems;
• Updating and enhancing customer records;
• Marketing our Services and those of selected third parties to existing and former customers, third parties who have previously expressed an interest in our Services, and third-parties with whom we have had no previous dealings for our legitimate interests.

We do not use your Personal Data for any automated decision-making purposes.

V. How We Store and Protect Your Personal Data

Personal Data may be held at our offices and those of our third-party service providers or representatives and agents. Your data collected by us will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. You acknowledge and agree that, to the extent not prohibited by local laws and regulations, your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering and/or our affiliates around the world.

We will keep your Personal Data while you have an account with us or while we are providing you services. Thereafter, we will keep your Personal Data for so long as is necessary to respond to questions, complaints, show fairness, or keep records required by law. We will not retain your Personal Data for longer than necessary.

Different retention periods apply for different types of Personal Data:

• Login, Account, Payment, Support, Advertising, Automated, Survey, and Other information: Stored for so long as needed to provide our Services or we are required by law.

The security of your Personal Data is important to us and we implement security safeguards designed to protect your Personal Data and regularly monitor our systems for possible vulnerabilities and attack. However, we need to remind you that no method of transmission over the internet, or method of electronic storage, is 100% secure.

VI. How We Share, Transfer and Disclose Your Personal Data

When sharing, transferring, and disclosing your Personal Data, we uphold the principles and requirements of minimization, necessity, and legality.

How We Share Your Personal Data

WE DO NOT SELL ANY PERSONAL DATA TO THIRD PARTIES. We will share your Personal Data with only where necessary, such as with:

• Third parties that provide services in support of the Services (cloud services, user authentication, customer support, marketing, translations, payment processing, fraud detection, etc.). All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
• Companies within our corporate group who process your personal information in order to operate the Services.

How We Transfer Your Personal Data

We will not transfer your data to any other parties, except where we have obtained your explicit consent, if we are involved in a merger/acquisition, or as explained in this Policy.

How We Disclose Your Personal Data

We may need to disclose data about you when required by law, subpoena, or other legal process or if we have a good faith belief that the disclosure is reasonably necessary to investigate illegal activities, enforce agreements, defend claims, protect security, or protect rights/safety. Additionally, we may share data with our attorneys, accountants, investors, or other third parties with your authorization.

VII. How Your Data Is Transferred Across Borders

For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your Personal Data to our servers for storage or processing. We may also transfer your Personal Data to third-party service providers and business partners in other countries or regions. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.

VIII. How We Handle the Data of Children

Our Services are not intended for children under the age of thirteen (13) or the minimum age in the relevant territory if that age is older than thirteen (13) (the "Child" or "Children"), and we do not knowingly collect any personal information from such Children. In the event that we learn that we have inadvertently gathered personal information from a Child, we will take reasonable measures to delete such information from our records.

IX. Your Data Protection Rights

You have specific rights regarding your personal information:

• The right to access or delete the data we have on you. You have the right to access your Personal Data that we hold about you. On receipt of a verifiable request we will delete your Personal Data from our records unless required for legitimate business interests.
• The right to rectify. You have the right to obtain rectification of your Personal Data without undue delay.
• The right to object and restrict. You have the right to object to our processing of your Personal Data or request that we restrict the processing.
• The right to data portability. You have the right to be provided with a copy of the data we have on you in a structured, machine-readable format.
• The right to withdraw consent. You have the right to withdraw your consent at any time.
• Right to control your privacy settings. You can control permissions like "Location Access" or "Storage".
• Right to close your account. You can close your account via instructions in our Services. Once closed, we will delete or de-identify your relevant data.
• Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights.

X. How To Exercise Your Rights

To easily access, view, update, correct, delete or port your Personal Data, please sign into your account and visit "Account Settings" or contact our customer service. To exercise the access, data portability, correction, and deletion rights described above please submit a verifiable request to us by emailing us at info@AxiumLtd.com.

We endeavour to respond to any verifiable request within one (1) month of its receipt. If we require more time, we will inform you of the reason and extension period required in writing.

XI. Cookies and Similar Technologies

Cookies are small text files to ensure that our software's normal operation and your convenient access to it. We and our partners may use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s). You can manage or delete Cookies according to your preferences. We do not respond to Do Not Track signals.

XII. Third-Party Service Providers and Services

You may receive links to third-party websites or content and services provided by third parties other than us during your use of our Services. You can choose whether to visit or accept such Third-Party Services at your sole discretion, and we encourage you to read and review the privacy statements of each Third-Party Service that you may choose to use.

XIII. How to Contact Us

For the purpose of establishing the Personal Data protection in a better and more efficient way, we, as the Data Controller, designate a Data Protection Officer ("DPO"). If you have any comments, questions or concerns with respect to our Privacy Policy or Personal Data protection practices, please contact our DPO at dpo@AxiumLtd.com. (All requests must be labeled "Privacy Policy request" on the email subject line for us to better assist you).

XIV. Extra Help

If you would like this Policy in another format (for example: audio, large print, braille) please contact us.