PRIVACY POLICY

1. Introduction

TANYWIN GAME, its partners, parent companies, subsidiaries, licensees, licensors and affiliates (collectively, the “Company”, “we” or “us”) develop, publish, market and commercialize a variety of games for use on various platforms, including mobile devices (our “Applications”) through which we offer relating game play and gaming services, including the ability to make purchases through the Applications; we may also operate websites for our Applications from time to time ("Sites") (collectively, the “Services”).

TANYWIN GAME determines the purpose and means of the processing of your personal information as described in this Privacy Policy, and therefore acts as a "data controller" of such data.

2. Notice

We recommend that you read this Privacy Policy in full to ensure you are completely informed about your personal information.

This Privacy Policy is intended to provide notice of the Company’s information practices, including the types of personal information gathered, how personal information is used and safeguarded, and how you may control the maintenance and sharing of your personal information. This Privacy Policy applies to personal information we collected through our Services and applies to all users of our Services globally.

3. What Information We Collect About You

We may collect information about you in the following ways: (1) directly from you, (2) automatically through your use of our Services, or (3) from third parties. The information we receive depends on factors such as the Service you’re using, third parties we partner with or you integrate with, and your privacy settings.

Information that you provide directly

We collect personal information directly from you when you choose to provide us with this information online and through your other interactions with us (such as data collected via social media and any surveys, customer service communications, competitions or other promotional programs in which you may participate). Certain parts of our Services ask you to provide personal information when you engage with the following services: account creation, customer service information and purchase of goods/services.

Information that we collect indirectly

We collect your personal information indirectly, including through automated means from your device when you use our Services. Some of the information we collect indirectly may be captured using tracking technologies, as explained further in the "Mobile IDs and Tracking Technologies" section below.

Information from third parties

We may also collect your personal information from third party sources, for example:

• Social Media and Third-Party Partners.> We may collect any of the below categories of information from third-party applications, including social networks, that you choose to connect or interact with through our services.

• Service providers. Third parties collect or provide any of the below categories of information in connection with work they do on our behalf. For example, we use vendors to provide customer service communications in our apps. They may collect the content of communications, your name, username, and contact information, and any other information you provide to them.

We do not collect any special categories of personal information, as defined by the GDPR, about you, such as health-related information or information about your race or ethnicity, or sexual orientation. We do receive the following “sensitive personal information,” as defined by certain U.S. state privacy laws: communications information, which are the content of your communications when you use our Services to send messages to others.

When you are asked to provide personal information, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

4. Mobile IDs and Tracking Technologies

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access data. Our apps contain software that enables our third-party analytics and advertising partners to access the mobile IDs.

5. How We Use Your Information

We use the personal information we collect for purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your information. Where we process the personal information of EU and UK users, depending on our purpose for collecting your personal information, we rely on one of the following legal bases:

• Contract – we require certain personal information in order to provide and support the services you purchase or request from us;

• Consent– in certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal information, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you;

• Legitimate interests – we will use or disclose your personal information for the legitimate business interests of either us or a third party, but only when we are confident that your privacy rights will remain appropriately protected. If we rely on our (or a third party's) legitimate interests, these interests will normally be to: operate, provide and improve our business, including our Services; communicate with you and respond to your questions; improve our Services or use the insights to improve or develop marketing activities and promote our products and services; detect or prevent illegal activities (for example, fraud); and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers and vendors. Where we require your data to pursue our legitimate interests or the legitimate interests of a third party, it will be in a way which is reasonable for you to expect as part of the running of our business and which does not materially affect your rights and freedoms. We have identified below what our legitimate interests are; or

• Legal obligation – there may be instances where we must process and retain your personal information to comply with laws or to fulfil certain legal obligations.

The provision of your purchase information is necessary for TANYWIN GAME to access the virtual items you have purchased and for the performance of our contract with you and/or to enter into a contract with you. If you do not provide this data, then we will not be able to perform a contract with you and provide the relevant services to you.

We combine data we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.


6. How We Disclose Your Information

We may disclose deidentified information, that is, information that cannot reasonably be used to infer information about or otherwise be linked to a consumer, about our players as permitted by applicable law.

We also disclose personal information with your consent or as we determine necessary to complete your transactions or provide the services you have requested or authorized. In addition, we disclose each of the above categories of personal information with categories of recipients (or allow third parties to collect this information from our Services) described below and for the following business purposes:

• Public information: Some of your profile information can be seen by other players in the game such as your profile name (either the default name or a name that profile name of your choosing), your profile image (the default image, an image you select, or the profile photo associated with a linked account) and the level of the game you are playing. You may select options available to edit your name and/or profile name, change your profile picture, and certain other information.

• Third party social media platforms: Only at your direction, we will share information including your profile name, your player ID, your profile picture and certain in-game content (such as the level of game you are playing, screenshots of your gameplay) to your accounts with third party social media platforms.

• Service providers: We may provide personal information to third party vendors, service providers, contractors or agents who perform functions on our behalf for the purposes described in this Privacy Policy. For example, this includes companies we’ve hired to provide customer services support and game play analysts.

• Financial services and payment processing: When you provide payment information, for example, to make a purchase, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.

• Affiliates: We enable access to personal information across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business.

• Corporate transactions: We may disclose personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

• Legal and law enforcement: We will access, disclose, and preserve personal information when we believe that doing so is necessary to comply with applicable law, a judicial proceeding, court order, or other valid legal process, including from law enforcement or other government agencies.

• Security, safety, and protecting rights: We will disclose personal information if we believe it is necessary to: to protect us, our users, and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone; to operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or to protect the rights or property of ourselves or others, including to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, enforce our agreements, terms, and policies, or as support or evidence in any dispute or litigation in which we are involved.

Third party analytics and advertising companies also collect personal information through our Services, including identifiers and device information (such as device IDs, MAIDs, and IP address), IP address, usage data, and inferences based on and associated with that data. Some of the disclosures to these third parties may be considered a “sale” or “sharing” of personal information as defined under the laws of California and other U.S. states. Please see the “What Choices Do You Have” and “California Privacy Rights” sections below for more details.

Please note that some of our services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal information to any of those third parties, link or bind your accounts, or allow us to share personal information with them, that data is governed by their privacy statements.

7. Retention and International Transfer of Personal Information

We retain personal information for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs vary for different information types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Details of retention periods for different aspects of your personal information are available from us on request by contacting us using the contact details provided under the “Contact Us” heading below.

To the maximum extent permitted by the applicable laws and regulations, we may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information and the use and disclosure of information about you, including personal information, as described in this Policy.

8. Location of Personal Information

The personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data. The storage locations are chosen to operate efficiently and improve performance. We take steps with the intent of processing and protecting as described in this Privacy Policy wherever the data are located.

We have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Privacy Policy and applicable laws.

9. Security of Your Personal Information

We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your password, mobile device and computer by, among other things, sharing your account with others, choosing a robust password that nobody else knows or can easily guess and keeping your password private. You should never share your password with anyone or use the same password with other sites or accounts.

10. Effective Date; Policy Changes

Each time you use our Services, the current version of the Privacy Policy will apply. Accordingly, when you use our Services, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version.

This Privacy Policy is subject to change from time to time. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. If we make material changes to the Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law.