Privacy Policy

Last Updated:2023

Effective date:2023

【Cloudary Singapore Private Limited】(hereinafter referred to as “we”, “us”, “our”) fully respect and are committed to protecting the privacy rights of our users (“users”, “user”, “you”) who visit our websites, access or use our games, whether played on mobile devices, PCs, our websites or any other applicable platforms and/or devices (“Devices”), and access or use any services offered by us, including but not limited to technology services, customer support, competitive gaming activities, marketing and advertising (collectively, our “Services”).

This Privacy Policy (“Policy”) is provided to help you understand our practices related to the collection, use, storage, and disclosure of information we collect from or about you when you interact with us, your rights regarding the information provided to us, and how we transfer and secure such information.

Please make sure to read this Policy carefully to understand our practices regarding your personal data and access it frequently to understand the updates to this Policy. By accessing or using any of our Services, you are deemed to have read, understood and accepted this Policy. If you do not agree to the terms of this Policy, please do not use any of our Services.

If we update this Policy, we will notify you by announcements in our games to let you know about the changes we have made and to obtain your consent again. By accessing or using our Services after we have posted such a notice, you are deemed to have accepted the updated Privacy Policy. You can check the “Effective Date” posted at the top of the Privacy Policy for the latest update time.

It is important to note that this Policy applies to any and all of the Services provided by us. However, this Policy does not apply to any products, services, websites, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies. We encourage you to read and review the privacy policies of each Third-Party Service that you may choose to use.

If you have any questions regarding this Policy, please feel free to contact us.

This Policy is designed to help you understand the following contents:

i. Important Definitions

ii. Data We Collect and Use

iii. How We Store and Protect Your Data

iv. How We Share, Transfer and Disclose Your Data

v. How Your Data Is Transferred Across Borders

vi. How We Handle the Data of Children

vii. Your Data Protection Rights

viii. Cookies and Similar Technologies

ix. Third-Party Service Providers and Services

x. Supplement and Update of The Policy

xi. How to Contact Us

xii. Jurisdiction Specific Supplemental Terms

I. Important Definitions

Ÿ Personal Data: 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.

Ÿ Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself.

Ÿ Cookies: Cookies are small pieces of data stored on a user’s device.

Ÿ Data Controller: 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 are, or are to be, processed. For the purpose of this Policy, we are Data Controller of your data.

Ÿ Data Subject: Data Subject is any living individual who is the subject of Personal Data.

II. Data We Collect and Use


For your better experience in our Services, we may require you to provide us with certain personal data while using our Services.

e may collect your Personal Data in the following ways: 1) information you voluntarily provide to us (such as your nickname, profile picture and phone number you provide to us when you register or login to your account); 2) information we obtain automatically during your use of our Services (such as device information and Usage Data); 3) information we obtain from other sources (such as our partners or vendors).

You are not required to provide your Personal Data to our Services, but in some cases, if you choose not to do so, we may not be able to provide you with related features or services, nor will we be able to respond to or resolve the problems you may encounter. We will collect and use your Personal Data only for the purposes described in this Policy. The following describes your Personal Data that we collect and how we use it.

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 the Game, you consent to provide some of your personal data, such as e-mail address, phone number, verification code by email or SMS, and password.

If you register via social network accounts, such as Apple Game Center, Facebook or Google Play (“Social Networks”), we may collect information that you have 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 Networks, but it would typically include your basic public profile information, such as your nickname, age, username and profile picture. If you refuse to provide information about your third-party account, you may not have the option to register and log in by your third-party account.

In 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 and for administration of the gameplay management system. If you are located in certain regions, we may ask you to provide an email address for the purpose of verifying parental or guardian consent to use the game services if you are under the applicable minimum age.

(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 any additional information on your profile; however, profile information helps you to get more from our Services, including helping others to know you better. It’s your choice whether to include sensitive information in your profile and whether to make that sensitive information public. Please do not post or add any Personal Data to your profile that you do 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, IP address, OS version, type of device, internet connection), transaction details (including 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 to provide you with details of your transactions.

All purchases and withdrawals are processed by our third-party payment processing companies (which may include PayPal, Apple Pay, etc.). We do not process the payments, nor do we have any access to your credit card information or billing information. Any post-purchase processes are controlled by the third-party payment processing companies and are subject to those processing companies’ specific terms of service. Please review the privacy policies and terms of service of the third-party payment processing companies you choose.

(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 resolution. 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)Sweepstakes, Tournaments, Competitions, or Contests Participation Information

When you participate in sweepstakes, tournaments, competitions, or contests and/or win any prizes, we may collect and process the following information that you voluntarily provide to us, such as your username, email address, telephone number, mailing address, UID, nickname and your country or region. We may display your UID and/or username in a partially-redacted format upon your permission. If you don’t win any prizes, we may not announce or display the above information in any form.

(6)Advertising Information

We may store the Advertising ID for that advertisement and select device information with your profile to track the success of our advertising if you click on advertisements in our Services and we will take appropriate technical security measures (such as encryption and hashing) to de-identify the collected information afterwards.

In order to provide you personalized advertisements, promotional activities and marketing communications, we and our advertising and marketing partners may collect and process the following information with your consent, such as age, gender, e-mail address, geographical location, device type, in-game information (such as your habits and preferences in the game) 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 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 in accordance with the instructions therein, such as via SMS, email, online contact channels and other contact methods we provide.

(7)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 Games and Services, including:

Ÿ Internet Protocol (IP) address.We collect and process this information to allow you to access or restrict your access to our Services.

Ÿ 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, 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 (IP address, GPS location and WLAN connection, Bluetooth and cell site information that provides location information).

Ÿ Usage Data. For the purposes of performing the 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.

(8)To Provide You with Notification Services

We may also send you service notifications, events and other messages based on the information that you provide to us. To unsubscribe from notifications, you can turn off such notifications on your device settings.

(9)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.

(10)To Provide You with Security Services

To improve the security of your use of our Services, to protect you, other users or public safety and property from harm, to better prevent security risks and to more accurately identify violations of laws and regulations or our relevant agreements, we may use or integrate information about your device as well as your Usage Data to help you conduct security risk detection, prevent security risks, and take the necessary recording, auditing, analysis and disposal measures in accordance with the law.

(11)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 with 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 and we will obtain your consent.

III. How We Store and Protect Your Data

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. To the extent not prohibited by local laws and regulations, we may also store the collected data in countries or regions outside the country where our business is located.

Currently, the Personal Data we collect from you may be stored on servers that may not be located where you live. The locations of servers for our Services include 【Singapore】. You acknowledge and agree that your data will be accessed from outside of where you live by our support, engineering and/or our affiliates around the world. Although the data protection laws of such countries or regions may be of lower standard than that of the country where you live. We will, however, ensure that your Personal Data set out in this Policy will remain protected in accordance with this Policy and any applicable laws. Also, we will take steps necessary to comply with applicable legal requirements, such as using European Commission approved Standard Contractual Clauses to protect your information.

We generally retain your Personal Data as long as we need to provide you with Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. While you can close your account by yourself, we may also close your account if you have not used your account for 180 consecutive days or to comply with this Policy, the Terms of Service, other related rules or applicable laws and regulations. In case of such account closure, we will delete or de-identify your relevant data.

However, if your account is terminated or you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests to the extent permitted by applicable laws, such as to resolve disputes, and enforce our agreements.

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 attacks. We are constantly working to improve on these safeguards to keep your Personal Data secure.

However, we need to remind you that that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. You should note that our third- party partners may be responsible for processing, handling or storing some of the that we receive. These service providers are contractually required to safeguard and secure the Personal Data they receive from us. Although we strive to protect your Personal Data, you should be aware, however, that information sent over the Internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not responsible or liable for any such interception or unauthorized access.

IV. How We Share, Transfer and Disclose Your Data

When sharing, transferring, and disclosing your personal data, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal data externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal data in the following situations:

1.How We Share Your Data

WE DO NOT SELL ANY PERSONAL DATA TO THIRD PARTIES. The Personal Data you provide to us may be shared with third party partners or our affiliated companies if this is necessary to provide you with our Services, to respond to your inquiries or for any of the purposes described in this Policy. This may include:

Ÿ We may share the necessary Personal Data with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. For example, in order to enable you to share information to third party platforms, use location service and other kinds of services and features, we may embed third party SDK or other similar applications of authorized partners in our Services. Please refer to “Third-Party Service Providers and Services” section for more details.

Ÿ We will share your Personal Data with our affiliates (i.e., any organization we own or control and/ or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns) to provide and develop our Services. These companies will use your Personal Data in the same way as we do under this Policy.

In order to provide evaluation, analysis or other business services, we may also share your non- Personal Data with third parties. We see this processing as necessary for the purposes of organizing our business as appropriate. Where we cannot rely on legitimate interests for the sharing in a particular case (because for example your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under applicable law.

2.How We Transfer Your Data

We will not transfer your data to any other parties, except in the following circumstances:

Ÿ Obtain your explicit consent.

Ÿ If we are involved in a merger, acquisition or sale of all or part of its assets, which may affect your Personal Data, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your Personal Data, and any choices you may have about your Personal Data. We will require the new company or organization holding your Personal Data to continue to be bound by this Policy before we require the company or organization to seek your authorized consent again.

Ÿ In the case that has been explained in this Policy or notified you by other means.

3.How We Disclose Your 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 disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services; or (5) exercise or protect the rights and safety of our games, our users, personnel or others. We attempt to notify users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

Additionally, we may share your data with:

Ÿ Our attorneys, lawyers, accountants, auditors, or similar consultants, when we request

them to provide professional advice.

Ÿ Investors and other relevant third parties, if actual or potential sales or other company

transactions occur and are related to entities within our group.

Ÿ Other third parties, for example, the disclosure of specific information with your


V. 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 stipulated in section III of this Policy for storage or processing, we may also transfer your Personal Data to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions.

In the circumstance that we transfer personal data outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.

VI. How We Handle the Data of Children

Our Services are not intended to be accessed by any children under the age of 13 and shall be directed to an adult or older in your country of residence (or at other age in your jurisdiction where you are classified as a majority). If you are a minor child or of the legal age of minority (“Child”), you must have your parent or legal guardian read through this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to create your Account. If you are a parent or guardian of a minor in your country, please make sure that you have read this Privacy Policy before allowing your children to create their own accounts or to use the Services and you have agreed to supervise your children’s use of the Services, if you wish to review data collected from your Child, or have that data modified or deleted, you may contact us as described below. If we become aware that a Child has provided us with Personal Data in violation of applicable law, we will delete any Personal Data we have collected, unless we have a legal obligation to keep it, and terminate the Child’s account.

VII. Your Data Protection Rights

We would like to make sure that you are fully aware of all of your data protection rights. As a Data Subject, you have a variety of rights regarding the use and control of your Usage Data.

In certain circumstances, you have the following data protection rights:

Ÿ 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. If you request a copy of your Personal Data, we will provide you with a copy in an electronic format after passing our verification process. However, if you choose to delete the data, some features that require such data may no longer be available.

Ÿ The right to rectify. If you consider that Personal Data we hold about you is inaccurate or incomplete, you have the right to obtain rectification with your Personal Data without undue delay.

Ÿ 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 of your Personal Data. You can ask us to stop using all or some of your Personal Data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Personal Data is inaccurate or unlawfully held).

Ÿ The right to data portability. You have the right to be provided with a copy of the data we hold about you in a structured, machine-readable and commonly used format.

Ÿ The right to withdraw consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your Personal Data. You can withdraw your consent previously granted to us for a specific purpose by deleting data, turning off device features, and requesting to withdraw consent, including the collection, use and/or disclosure of your Personal Data that we manage or control. If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of our products and Services. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.

Ÿ Rights to opt-out of marketing communications. You may opt out of receiving promotional communications, such as marketing e-mails from us by following the instructions in such communications, or by changing your in-game settings. The updated settings may not be effective immediately.

Ÿ Right to control your privacy settings. You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your Personal Data via such privacy settings. For example, you can choose to turn on or turn off the permissions of “Location Access” or “Storage”; you can obtain detailed data regarding the device security status or change such status in “Privacy Settings” on your device.

Ÿ Right to close your account. You can close your account via instructions in our Services or contacting us for help. Please understand that for security reasons, your account cannot be closed unless you follow our instructions. We hereby kindly remind you that, if you choose to close your account, such closure may prevent you from using our Services, and such closure is irreversible. Once you close your account, we will delete or de-identify your relevant data. If you sign in to the accounts through a third-party account (e.g., via Facebook, Google ID), you need to apply for account closure with such third party.

According to the applicable laws of some jurisdictions, you may have other data subject’s rights. Please refer to Jurisdiction Specific Supplemental Terms at the end of this Policy.

Please understand that for security reasons, we may ask you for additional information to confirm your identity and that we are providing access to information about the correct person before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or require the disclosure of information of third parties.

VIII. Cookies and Similar Technologies

Cookies are small text files to ensure that our software’s normal operation and your convenient access to it. Cookies usually contain identifiers, site names, and some numbers and characters. We may use Cookies and other similar technologies such as Pixel Tags and Web Beacons. We generally treat information collected by Cookies and similar technologies as non-Personal Data as they do not contain any of your personally identifiable information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by the laws of the countries concerned, we will also follow the laws of the countries concerned.

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) on, off and across different services and devices where you have engaged with our Services. You can manage or delete Cookies according to your preferences, but if a browser or mobile device is set not to accept Cookies or if a user rejects a Cookie, some portions of the Services may not function properly.

IX. 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, and some third parties’ products or services can be accessed in the form of SDKs and others in order to provide you with some functions and features, such as to provide you with third party logins, notifications and user analysis. The third-party service provider may be an independent controller of the Personal Data processed in order to provide the Services and it will individually determine the purposes and means of processing such data. Such data refers to any information or data that third-party service provider collects through the SDK implemented in our Services, e.g., user device information, user identifiers, information about advertisements served, viewed or clicked or other user interactions with advertisements or the Services, information about user applications, network information and header information.

You can choose whether to visit or accept the third-party websites, products, and services at your sole discretion. This Policy does not apply to products and services provided by any third party. Since we are not able to substantially control a third party, we are not responsible for the third party’s collection and processing of your Personal Data.

X. Supplement and Update of the Policy

We reserve the right to update or modify this Policy from time to time in order to reflect the changes in our business, technology and applicable laws and practices. In case of any modification of this Policy, we will notify you by announcements in our Apps or our websites to let you know about the changes we have made. Although this Policy may be modified, your rights under this Policy will not be diminished without your explicit consent. By accessing or using our Services after we have posted such a notice, you are deemed to have accepted the updated Policy.

XI. 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 (in short, “DPO”) who is responsible for the oversight and implementation of the personal data protection strategy and ensures our processing of personal data in compliance with necessary legal requirements stipulated in the applicable laws. If you have any comments, questions or concerns with respect to this Policy or practices of personal data protection, please contact us at 【】(All requests must be labeled “Privacy Policy request” on the email subject line for us to better assist you).

We will review your privacy or personal data requests as soon as possible and respond to you within 15 days after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.

XII. Jurisdiction Specific Supplemental Terms

According to the applicable laws of some jurisdictions from which you access or use the Services, we may supplement this Policy with jurisdiction specific terms. Such supplemental terms constitute an integral part of this Policy. In the event of a conflict between the provisions of the Supplemental Terms and the rest of this Policy, this Supplemental Terms shall prevail.

(1)For Users in the United States:

If you are a California resident, you are entitled to request notice of certain information about the user information that we may share with third parties for marketing purposes (e.g., the categories of user information shared, and contact information of applicable third parties), as well as request that we disclose to you what Personal Data we collect, use, disclose and sell about you, the right to opt out of the sale of your information, and the right to request deletion of Personal Data we collect or maintain about you. If you would like to exercise any of these rights, please email your request to us as provided in XI. How to Contact Us.

You also have the right to not be treated in a discriminatory manner for having exercised your rights regarding your privacy rights under the California Consumer Privacy Act (CCPA).

While we have tried to fully describe our data practices elsewhere in this Privacy Policy, this section supplements the description of our information collection and sharing practices elsewhere in this Policy, as required under applicable U.S. state laws.

As noted above, we may also disclose your Personal Data as part of, or during negotiations of, any merger, sale, divestiture, or transfer of all or a portion of the company assets, financing or acquisition or in any other situations where Personal Data may be transferred as one of the business assets of us.

As a California resident, you may request that we disclose to you the following information for the 12 months preceding your request: (i) the categories of Personal Data that we have collected about you and the categories of sources from which we have collected such Personal Data; (ii) the business or commercial purpose for collecting, sharing, or selling Personal Data about you; (iii) the categories of Personal Data about you that we have sold or shared (as defined by California law) and the categories of third parties to whom we have sold or shared such Personal Data; and (iv) the categories of Personal Data about you that we have otherwise disclosed and the categories of third parties to whom we have disclosed such Personal Data.

We will not unlawfully discriminate against you for exercising your rights, including, but not limited to, by:

Ÿ Denying products or services to you;

Ÿ Charging different prices or rates for products or services, including through the use of discounts or other benefits or imposing penalties;

Ÿ Providing a different level or quality of products or services to you; or

Ÿ Suggesting that you will receive a different price or rate for products or services or a different level or quality of products or services.

Please submit your request by sending an email to Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Service. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. Not all kinds of requests can be made by authorized agents in all states. We will respond to a verifiable consumer request within 45 days of its receipt when possible. If we require more time (up to 45 additional days), we will inform you in writing, within 45 days of receipt of the original request, of the extension period and the reason for the extension. We do not charge a fee for responding to or processing your verifiable consumer request unless it is manifestly unfounded, excessive, or repetitive. In such a case, we may charge a reasonable fee or refuse to act on the request, but we will inform you of the reasons for that decision and provide you with a cost estimate before completing the request.

[If you are a Colorado, Connecticut or Virginia consumer and] If we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at

(2)For Users in the European Union (EU), the United Kingdom (UK), European Economic Area (EEA), and Switzerland:

If you are a resident in any of the above countries, you may also have a right to complain to a data protection authority about our collection and use of your user information. For example, you can lodge a complaint with your local supervisory authority (EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC)).

In addition, the following additional information applies to you in addition to the Policy set out above.

Ÿ Data Subject Rights

In addition to the information set out in Section VII in the Policy above, you may also have a right to complain to a data protection authority about our collection and use of your user information. For example, you can lodge a complaint with your local supervisory authority (EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC)).

Ÿ Legal basis for processing your Personal Data

If you are an individual in the above countries, we collect and process personal data about you only where we have legal bases for doing so under applicable laws. The legal bases which we rely upon are the following:

Ÿ Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you.

Ÿ Legal Obligation. This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data.

Ÿ Legitimate Interests. This covers data used by us to protect our or our partner’s legitimate interests (e.g. to improve our services), and your vital interests or those of another person/player (e.g. against fraud and violations of our terms).

Ÿ Your Consent.

These are used as the legal basis in the Section II in the Policy above.

(3)For Users in Indonesia

If you are an Indonesia resident, you are entitled to sue us and receive compensation in case we violate the laws to process your Personal Data. You also have the right to delay or restrict processing under the Indonesia Personal Data Protection Bill, you acknowledge and agree that you may only exercise this right in a proportional manner to the original purpose of processing.