ANCILLARY PRIVACY DISCLOSURE DOCUMENT FOR CALIFORNIA RESIDENTS

Last updated: 08/05/2020

The California Consumer Privacy Act of 2018 (CCPA), as amended, establishes specific rights for California residents, for the control of their personal data, and requires businesses to provide specific information to California residents regarding how their personal data is collected, used, and shared.

Puzzle Point Ltd , a limited liability company duly incorporated in the Republic of Cyprus under the Companies Law Cap. 113, with company registration number HE 404860 and registered office address at 159, Leontiou A' Street, Maryvonne Building 3rd Floor, Office 302,3022, Limassol, Cyprus (hereinafter referred to as "Puzzle Point", "Us", "Our" or "We"). This Ancillary Privacy Disclosure Document (hereinafter referred to as "Disclosure"), provides Disclosure to residents of California who use Our Services (hereinafter referred to as "You"), to provide You with the information required by the CCPA and to inform You of Your rights under the CCPA. This disclosure supplements Our Privacy Policy, which provides more detailed information on how and why We may process data relating to You. We recommend that You read our Privacy Policy, available at https://puzzlepoint.com/privacy-policy.html, in conjunction with this disclosure.

In this disclosure, the terms "Services" or "Games" or "Websites" have the same definition as in Our Privacy Policy.

1. Your rights

Under the CCPA, California residents have certain rights to their personal data. If You are a California resident, You may exercise these rights as explained below.

When You submit a request to exercise Your rights, We are required to verify that You are the consumer to whom the request for personal data relates, or a person authorized to act on that consumer's behalf. If You submit Your request by using automated tools that may be provided in Our Games, We may not need additional information to verify Your request. For requests submitted by other means (for example, by email), We may ask You to provide additional information about the account to which the request relates to, in order to enable Us to confirm that You are the account holder or acting on their behalf.

Right to Know. You have the right to know what personal data We collect about You, from which sources, for which purposes, and with whom We share it. You also have the right to request the specific pieces of personal data that We have collected about You. This request can be made free of charge, twice within any 12-month period. Moreover, You have the right to know which categories of personal data We may have "sold", or disclosed for a business purpose.

For information on what personal data We collect, from which sources, for which purposes, with whom We share it, and whether We disclose it for business purposes, please refer to clause 2 of this Disclosure. In addition, clause 3 of this Disclosure describes the extent to which We may "sell" Your personal data within the meaning of the CCPA.

You may request a copy of Your personal data either by using automated tools that We may provide for this purpose in our Games, or alternatively, You can do so by contacting our support. For more information, please refer to clause 9 of Our Privacy Policy.

Deletion. You have the right to request that We delete any personal data about You, that We have collected from You, subject to certain exceptions provided in the CCPA (including, for example, where We need to keep Your personal data to protect against malicious, deceptive, fraudulent, or illegal activity or to comply with a legal obligation).

You may request deletion of Your personal data by using automated tools that We may provide for this purpose in Our Games. Alternatively, You can do so by contacting Our support. For more information, please refer to clause 9 of Our Privacy Policy.

Following Your deletion request, We may either erase or de-identify Your personal data.

Right to Opt-Out. You have the right to direct Us to not sell Your personal data. Doing so means that We will no longer share Your identifiers and other data with Our ad partners, to make the ads You see more relevant to You. To exercise Your right to opt-out, You may use automated tools that We may provide for this purpose in Our Services, or by contacting Our support. Where available, the tool can be found by navigating to the game settings and tapping "Terms and Privacy" or a similarly named option. If You have trouble using the tool, please refer to clause 9 of Our Privacy Policy for contacting Our support.

Non-Discrimination. You have the right to not be discriminated against, for exercising Your rights under the CCPA.

2. How We collect, use, and share Your personal data

What follows is a summary of how We collect, use, and share Your personal data. The summary is provided in the format We believe to be required by the CCPA. Please review Our Privacy Policy for additional information.

We regularly collect the following categories of personal data specified in the CCPA:

Category of personal data	Examples	Sources
Identifiers	In-game alias, IP address, hardware or operating system based identifiers, email address, or identifiers We assign to Your account.	Directly from You (including automatically when You interact with our Services), Our advertising partners (to the extent You interact with Our ads outside of Our Services), third-party account providers (if You link a third-party account to Our Services), or third-party payment service providers (if You make purchases in Our Services).
Commercial data	Data regarding Your virtual items or currency in Our Services, including records of purchases You may have made.	Directly from You (including automatically when You interact with Our Services) and third-party payment service providers (if You make purchases in Our Services).
Internet or other electronic network activity data	Data on Your activity in Our Services (for example, Your game progress or Your interactions with ads in Our Games).	Directly from You (including automatically when You interact with Our Games), Our advertising partners (to the extent You interact with Our ads outside of Our Games).
Geolocation data	Your coarse location (for example, country, state, or city), determined based on Your IP address.	Directly from You (including automatically when You interact with Our Games).
Inferences drawn from this data to create a profile about You	Your geolocation or preferences used to personalize Our Games for You.	We make these inferences based on the other categories of data.

We shall use this data for the following business purposes specified in the CCPA:

• auditing related to an interaction with You and concurrent transactions,
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity,
• debugging to identify and repair errors in Our Services,
• short-term, transient uses,
• performing Our Services,
• internal research for technological development and demonstration, or
• activities to verify or maintain the quality or safety of Our Services, and to improve, upgrade, or enhance Our Services.

We will share the data with recipients such as Our service providers to achieve these business purposes. This means that We will disclose the categories of personal data listed above for a business purpose.

In addition, some features of Our Games (for example, in-game chat, surveys, or tools used to contact Our player support) may allow You to submit to Us data about Yourself. We will collect any data You choose to submit to Us using these features. Additional to the personal data listed in the table above, this may include other categories of personal data specified in the CCPA, including:

• characteristics of protected classifications under California or United States federal law (for example, sex or age),
• any categories of personal data described in subdivision (e) of Section 1798.80 of the California Civil Code,
• professional or employment-related data, or
• education data (defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act).

We only collect these categories of personal data directly from You, and You may choose not to submit this data to Us at Your discretion. We may use the personal data You choose to submit for performing Our Services (for example, to handle your support enquiries) and short-term, transient uses, and We may share the data with recipients such as Our service providers to achieve these business purposes. This means that We may disclose these categories of personal data for business purposes.

3. How We may "sell" Your personal data

Under the CCPA, a business is required to provide notice to a consumer before the business sells the consumer's personal data to third parties. The CCPA defines a "sale" as not only exchanges for monetary consideration, but also disclosures of personal data for other valuable consideration.

We do not sell Your personal data in exchange for money. However, when We request Our advertising partners to show You an ad in Our Services or Games, We disclose a limited amount of Your personal data to the advertising partners, to enable them to deliver an ad that is relevant to You. This includes the following categories of Your personal data:

• identifiers (generally including an advertising ID and Your IP address); and
• internet or other electronic network activity data (including technical information required to select and deliver the appropriate ad type and format).

Because this disclosure of data could be deemed a "sale" in the meaning of the CCPA, We provide the means for You to direct Us not to disclose Your personal data to Our advertising partners for this purpose. To learn how to exercise Your right to opt-out, please see clause 1 of this disclosure.

If We have actual knowledge that you are under the age of 14, We shall not sell your personal data without affirmative authorization.