PUZZLE POINT LTD PRIVACY NOTICE

This Privacy Notice describes how 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 Spyrou Kyprianou, 61, SK House, 4003, Limassol, Cyprus (hereinafter referred to as "Puzzle Point", "Us", "Our" or "We") collects, stores, uses, discloses or otherwise processes the personal data of end users of Our Services as defined below (hereinafter referred to as "You"), and what rights You have if We are processing Your personal data.

This Privacy Notice does not address data collection through other sources.

In this Notice, "Services" refers to Our Games, Websites, and any related services or properties We control; "Games" refers to Our games, applications, and other products, including Tropicmania and/or others; and "Websites" refers to a website or websites and other online properties We control, including puzzlepoint.com. The expression "Your Data" is used when referring to personal data that relates to You as an identified or identifiable individual.

It is important that You read this Notice before accessing or using the Services so that You are aware of how and why We may use data relating to You. In addition to this Notice, We encourage You to carefully review Our "Terms of Service", which govern Your use of Our Services.

Who we are

Puzzle Point is a free-to-play mobile games publisher, which specializes in addictive puzzle games for broad audiences. We develop and operate top-class games, which are easy to learn and hard to master, for people all around the world. The company was founded in 2019 by game industry veterans, with vast experience and dozens of successful games in their portfolio.

1. Data Controller

By "Data Controller", We mean an entity that determines how and why personal data is processed. With regard to the activities described in this Notice, We are the Data Controller.

During the provision and operation of the Services, it may be necessary to share Your Data with Our associates or partners. Some of these associates or partners are data controllers operating independently, and thus they may independently determine how and why they process Your Data. For more information on these partners and the ways in which they may process Your Data, please refer to clause 6 of this Notice.

2. Contact Information

For matters related to this Notice, You may reach Us by email at info@puzzlepoint.com.

In addition You may contact Our appointed Data Protection Officer ("DPO"), who oversees Our data protection related matters. For any questions or concerns about how We use Your Data, You may contact Our DPO by email directly at info@puzzlepoint.com.

3. Why Do We Collect And Process Personal Data And What Is Our Legal Basis For Doing So?

We collect and process Your personal data to enable Us to perform Our contractual obligations with You, in order to:

Pertaining to Our legitimate interest to make Our Services the best they can be, We may process Your Data to:

Pertaining to Our legitimate interest to make sure You have the best possible user experience in Our Games, We may process Your Data to:

Pertaining to Our legitimate interest in making sure that Our Services are a fair and safe environment for all users, We may process Your Data to:

Pertaining to Our legitimate interest to promote Our Services and to make sure We reach Our targeted prospective audiences, We may process Your Data to:

Pertaining to Our legitimate interest for the provision of related ads in Our Games and for the funding of Our Services in order to continue their provision to You, We may process Your Data to:

Pertaining to Our legitimate interest to safeguard Our operations, We may process Your Data to:

By providing Your consent, We may process Your Data:

Finally, We may process Your Data where necessary to:

Furthermore, We may process Your Data for additional purposes which are compatible with any of the purposes listed above.

We do not use Your Data to make automated decisions which significantly affect You. By an "automated decision", We mean a decision made by an information system without any human intervention.

3.1 Advertising And Marketing

Advertising provides funding for Our Services and thus allows Us to make Our Games available without charge. Within Our Games or Services, We display Our own ads along with ads from third parties. Additionally, We advertise outside of Our Games and Services, on third-party websites and applications. Through this section We provide further information on how Your Data may be used for advertising purposes, and how You may control the use of Your Data for such purposes.

Mobile advertising relies on the use of certain online identifiers, more particularly Advertising IDs but also IP addresses or other identifiers. When We make mention to an "Advertising ID", We refer to an alphanumeric string of digits provided by the operating system of a device. This is consistent across applications from different publishers. The Advertising ID is known as the Identifier for Advertisers (IDFA) on iOS devices and Google Advertising Identifier (GAID) on Android devices.

Advertising IDs are used for interest-based advertising and other advertising related purposes. You may control the extent to which Your Advertising ID is used for these purposes. By using the privacy settings of Your device, You may normally reset and/or limit the use of Your Advertising ID. For instance, You may "limit ad tracking" on iOS devices or "opt out of interest-based ads" on Android devices. These settings are specific to each device, which means that You should set them to Your desired state on each of Your devices individually. Do note that it can take some time for Your updated settings to take effect. Please consider that resetting or limiting the use of Your Advertising ID will not stop You from seeing ads, yet the ads You see could be less relevant to You.

When ads are displayed within Our Games and/or Services, We may disclose Your Advertising ID and IP address with Our advertising partners. On their part, Our advertising partners could also collect information directly from Our Games through technologies such as software development kits (SDKs), which are collections of software development tools. In either case, they can use Your Data for numerous purposes, such Us reducing the number of times an ad is displayed to You or to personalize the ads You see, so as to make them more relevant to You (for instance, based on the previous activity they have associated with Your Advertising ID). For more information, please refer to the privacy policies of Our advertising partners.

When Our ads are displayed to You outside of Our Services (for instance, on third-party properties such as websites or applications), the ad network involved in delivering that ad to You might, based on information previously processed such as earlier activity that they have associated with Your Advertising ID, have concluded that Our Services may be of Your interest.

Your Data may be used by Ad networks to:

Moreover, ad networks may choose to deliver their services where they utilise Advertising IDs, or other types of identifiers, in order to locate users who may be interested in Our Services where their previous activity or interests are similar to those of other users that are known by the ad network to use Our Services.

Advertising IDs or other identifiers are also used for ad measurement, for both ads in Our Games and Our ads outside of Our Services, necessitating the collection of metrics such as total views, clicks, or installs generated by a particular ad. Such measurement data might be directly or indirectly received or collected by numerous parties involved in ad delivery, including Us and Our advertising partners, through multiple means and technologies, such as web beacons inserted into ads. The collected data is used for a number of purposes, for example, to provide measurement services, to detect, investigate and prevent fraud or fraudulent behaviour, or to facilitate payments between the parties involved in ad delivery.

3.2 Cookies And Similar Technologies On Our Websites

As with most websites today, Our Websites may use cookies or similar technologies (for instance, local shared objects or web beacons). "Cookies" or a "cookie" is small piece of data sent from a website which is subsequently stored on Your computer by Your web browser. Cookies may be created by either the website You visit (first-party cookies) or by third parties involved in providing content, functionality, or services such as analytics or advertising for the website You visit (third-party cookies). A Cookie is typically used to identify or "remember" Your device, for instance to enable functionality, to facilitate audience measurement, to improve performance, or to store Your preferences.

3.3 How To Manage Cookies

Through Your device or browser settings, You may control the use of cookies, for instance by disabling some or all cookies or by configuring Your web browser or device to notify You when cookies are being installed. Though, You should note that by disabling cookies You may affect Your ability to use the Services.

4. What Data Do We Collect?

We may collect the following data in relation to You:

We do not anticipate or have any intention to collect or otherwise process any special categories of data relating to You. Special categories of data concern data relating Your genetic, biometric, or health information, revealing racial or ethnic origin, sex life information, sexual orientation, political beliefs, religious or philosophical beliefs, trade union membership, or information about Your criminal offences or convictions. Please do not this type of information to Us or use the Services to make By special categories of data, We mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about Your criminal offences or convictions. Please do not provide this kind of information to Us or use the Services to present such information to others.

5. From What Sources Do We Collect Your Personal Data?

We may collect Your Data from the following sources:

We note that You are not obligated to provide data to Us. However, We may not be able to provide You with the Services, or some elements or parts of the Services, without the collection and processing of Your Data. When You make use of Our Services, We will collect data relating to You for several or all of the purposes described within this Notice, depending on the Services You decide to use and Your choices when using them. We provide You with a number of options that allow You to limit or control the extent to which Your Data is processed. For instance, You may opt to not connect Your third-party accounts with Our Games, change Your device settings to reset or limit the use of Your Advertising ID, or to disable certain or all cookies from Your browser settings.

6. Who Do We Share Your Data With?

We may choose to share Your Data with third parties in order to accomplish the purposes defined within this Notice. These third parties may include:

Moreover, please note that specific data that You may submit or make available through Our Services can be visible to other users of Our Services. For instance, Your public profile information in Our Games, such as Your in-game username or alias, potential chat messages, as well as any information You have disclosed to provide social features such as groups or leader boards.

In relation to the processing activities described in this Notice, Your Data may be transferred to and/or processed in countries outside of the European Union (EU) and the European Economic Area (EEA). For instance, several of Our servers that We use for hosting data are located in Germany, and some of Our group companies or the service providers We use to provide the Services may be located outside of the EU and the EEA. These countries may implement data protection laws that are different from the laws of Your country. In such cases, We will incorporate the appropriate safeguards and means of protection of Your personal data. These safeguards may include compliance with the European Commission's Standard Contractual Clauses (SSCs) aimed at protecting personal data leaving the European Economic Area (EEA) through contractual obligations in compliance with the GDPR's requirements in territories which are not considered to offer adequate protection to the rights and freedoms of data subjects. Upon request, We can provide You a copy of the European Commission's standard contractual clauses and further details on the applicable safeguards.

7. How Long Do We Keep Your Data?

Your Data will be kept for so long as it is necessary for achieving the purpose for which it was collected such as to enable Us to provide You with the Services, or to comply with legal, reporting, or accounting requirements. We will occasionally review the collected data and delete or de-identify inactive accounts, or other data in Our Games or other Services.

Following the appropriate retention period, We will either de-identify or delete Your Data or, if neither de-identification or deletion is possible, for instance due to data being stored on a backup server, We shall isolate Your Data and halt further processing until their de-identification or deletions is made possible. It should be noted that We may continue to make use of data which is not identifiable to You, such as aggregate data.

8. How Do We Keep Your Data Secure?

We have employed all appropriate security procedures and measures to provide Your Data with a level of security suitable for the level of risk applicable with the processing activities described within this Notice. These measures are aimed at protecting Your Data against unlawful or accidental destruction, loss, alteration, including unauthorised disclosure or access. We employ a varying degree of measures, which typically include encryption in transit, pseudonymization of identifying data where possible, controls for limiting the access to systems or services that contain personal data and maintaining procedures and practises to handle suspected security incidents.

9. Your Rights

In the case that We are processing Your Data, You have the right to:

Where the processing We conduct on Your Data is done following Your consent, You may withdraw Your consent at any given time. We bring to Your attention that the processing of Your Data may continue regardless of the withdrawal of Your consent, where We have a lawful basis to do so.

In order to access Your Data in Our Games and/or Services, or to request its erasure, please use the automatic tools provided in Our Games and/or Services. Each of Our Games has specific tools, located in the game setting under "Terms & Privacy" or a similarly named option. You may also opt out of Our personalized offers, where applicable. We urge You to primarily use these specific tools to submit requests, since that will help Us to validate, process, and fulfil Your request a more reliable and quick manner.

In the case You wish to exercise any of Your rights, You may also contact Us at info@puzzlepoint.com. In order to fulfil requests which are submitted by email, We may need to confirm Your identity so as to verify Your right to make the request, which may involve requesting additional information from You. For instance, We may ask You to provide sufficiently detailed information about the account to which the request relates in order to enable Us to confirm that You are indeed the account holder or that You are acting on their behalf. While this is not Our usual practise, We reserve the right to charge You an appropriate fee for the exercise of Your rights where permitted by applicable laws and regulations.

Lastly, You always have the right to submit a complaint with Your local data protection authority regarding Our processing of Your Data. For more information, please contact Your local data protection authority, for instance, the Office of the Commissioner for Data Protection of the Republic of Cyprus.

10. Age Limit

Pursuant to Our Terms of Service, You declare that You are at least 14 years of age. However, We may not know the specific age of individual users of Our Services. If You are under 14 years of age, please do notprovide Us with Your personal data including Your name, home address, telephone number, or email address, or use the Services to make Your personal data available to others.

If We discover that We hold personal data relating to a user under the age of 14, provided that We have previously obtained parental or guardian approval, We will take appropriate measures to ensure that We process that data according to the requirements of applicable laws and regulations, or promptly delete the data from Our records. If You have reason to believe We hold personal data relating to a user under the age of 14, please contact Us by email at info@puzzlepoint.com.

11. Contacting Us

If You wish to proceed with the erasure of Your account, You may request this at any moment. In case You have any questions or concerns about this Notice, please email Us at info@puzzlepoint.com.

12. Notice Updates

Puzzle Point reserves the right to update this Notice from time to time, for example due to changes in Our operations or the legal obligations that apply to Us. Updates will be made available here. We may also inform You of any changes by other means that are appropriate to the significance of the changes. We urge you to review Our Privacy Notice on a frequent basis, and in particular before You submit additional information through our Services.