privacy

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by FreeLabs Inc. Curacao (‘​FL.inc​’ / ‘​we​’ / ‘​us​’) a company undergoing incorporation. Our registered office will be Landhuis Groot Kwartier, Groot Kwartierweg 12, Curaçao. We are a company registered in Curacao, with company number XXX​.

This privacy and data policy (“​Privacy Policy​”) applies and has effect in respect of all games, related online services (including online ​

network play connectivity and interactivity) and other software and products made available by us (together the "​Game(s)​"), as well as any other online features relating to the Games including our ​website (the "​Website​"), our online ​forums​ (the “​Forums​”) and ​User Support Centre​ (the "Support Centre​") all found on the website www.freeca.sh. Together the Game(s), the Forums and Support Centre are referred to as the “​Online Services​” all found on the Website.

If you have any questions or comments about this Privacy Policy, please contact our Data Protection Officer at [email protected]

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “controller”.

Please read this Privacy Policy carefully as it contains important information about the following:

What information we may collect about you;

• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using

these services. We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Games.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data.

a) Information provided by you when using the Games (“Basic Information”)

We will collect the following information from you when you play our Games:

• your mobile device’s unique device ID (Device ID) and device name;
• your date of birth; (for compliance purposes)
• your user preferences; and
• Core information related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores or the completion of certain activities during your gameplay (for example, completing a tutorial, passing a level, making a purchase or viewing a video ad)
• Your activity on the platform

b) Contact information provided by you when using the Forums, Support Centre, or redeeming prizes (“Contact Information”)

We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Forums, Support Centre, or prize redemption facility

This may include:

• your avatar/profile picture (Forums only);
• your username (Forums, and prize redemption only);
• your email address;
• your proof of address (prize redemption facility only);
• your proof of age (prize redemption facility only);
• your date of birth (prize redemption facility only);
• your postal address (prize redemption facility only);
• your telephone number (prize redemption facility only);
• your full name (Forums, and prize redemption only), and your password (Forums only).

c) Information used for the purposes of serving advertisements

(“Advertising Data”)

Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:

• the make, model and operating system of your device;
• properties of your device, such as screen size and orientation, audio volume and battery;
• the mobile network operator linked to your device;
• the Games played;
• the country, time zone and locale settings on your device (i.e. country and preferred language);
• network connection type and speed;
• IP Address;
• MAC address;
• internet browser used to access the Games; and
• the advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.

d) Information collected for the purposes of providing analytics

(“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following:

• your Device ID;
• your user ID (which is generated by us and allocated to you when you first play our games);
• your device operating system & version;
• your device make and model;
• game play attempts, progression and results;
• session game time start, end and duration;
• purchase transaction types and spend you have made using virtual items in the Games;

• the country of your Device;
• the time, date and install source of your first download (e.g. from a clicked advertisement);
• advertisements viewed and clicked; and
• identification of crashes and defects.

The collection of this information may include the use of cookies and similar technologies (for example, which are used on the Website). A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Cookies are widely used in order to make websites work, to provide functionality, to make them more efficient and to provide website owners with information about how the website is being used and who's using it.

The following cookies are used on our Website:

Cookie Purpose URL for third party terms

Google Analytics Cookies Use information in aggregate to optimise our website performance and reach https://support.google.co m/analytics/topic/291963 1?hl=en&ref_topic=10080 08

Google / YouTube cookies Enables visitors to use their Google account to save/share any embedded videos on our site https://policies.google.co m/privacy?hl=en

Most web browsers allow you to control cookies through your browser settings. To find out more about cookies generally and how to manage or delete them, you can visit ​here

3. WHY WE COLLECT INFORMATION ABOUT YOU

a) To provide our Online Services to you

We will use information about you (including Basic Information, Third Party Log In Information, Analytics and User Content) for delivering our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games.

We will use information about you (including your Contact Information, User Content and Third Party Log In Information) to provide you with the Forums under the terms of use agreed between us. The processing of information in this way is necessary for us to provide you with the Forums’ functionality and to ensure that you have the best experience when using the Forums.

b) To help us improve the Online Services and fix any problems

We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Online Services.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any Game(s) on our platform and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Online Services; and iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.

c) To respond to your enquiries and requests for support

We may process Contact Information so that we are able to properly respond to your enquiries and support requests either via the Support Centre or Forums or through ​[email protected]

d) To acquire new users and engage current users

We may process information (including some Advertising Data and Analytics) to encourage engagement from our less active users and to notify them with new virtual items or other promotions on offer.

We may process this information to pursue our legitimate interests of acquiring new users for our Games.

We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you.

e) To improve the monetization of the Games via in-app purchases

We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via in-app purchases. This may include the implementation of dynamic pricing models, so that in-app purchases are priced according to relevant factors, such as geography and gameplay progression so that we can offer temporary promotional discounts.

We will not pass your information to third parties for the purposes of dynamic pricing unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.

f) For advertising purposes

We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games.

The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify you or permit you to be treated individually.

We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games.

We will not pass or process your information for the purposes of marketing in general unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.

We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content.

g) To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and also in order to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may

not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.

4. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors:​ We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and subject to a contract compelling them to the same level of data protection provided under this Privacy Policy.

Merger or acquisition:​ If we are involved in a merger, acquisition, or sale of all or a portion of its assets, any third party to which we sell or transfer our assets to will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy Policy.

Required by law:​ In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement:​ We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of FL.inc, our customers, or others.

Digital Content Stores:​ Where the Games are downloaded though Google Play, iTunes and/or Amazon Appstore, we may disclose your personal information to Google, Apple and/or Amazon respectively for the purposes of facilitating any in-Game payments made through these platforms.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

You will have the option to opt-in and/or out of lookalike campaigns, receive notifications from us or be served with targeted advertisements​.

You can opt-in and/or out from analytics in your settings.

You can change your consent to opt in or our of targeted advertising by changing your advertising settings on your device at any time.

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.

To make a request, please let our Data Protection Officer know by sending an email to ​[email protected]​.

a) Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

b) Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

• you consented to our processing the personal data, and have withdrawn that consent;
• we no longer need to process that personal data for the reason it was collected;
• we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of FL.inc or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
• the personal data was unlawfully processed;
• you need the personal data to be deleted in order to comply with legal obligations;
• the personal data is processed in relation to the offer of a service to a child.

c) Obtain a machine readable copy of your personal data, which you can use with another service provider

If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

d) Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

8. DATA RETENTION

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

For more information about data retention terms in relation to specific Personal Data, please contact Us at [email protected]

9. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of 18. Our terms of use prohibit users aged under 18 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 18 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18 years of age please contact us at ​[email protected].

10. SECURITY

We will take technical and organizational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as FL.inc management or employees whose main role requires system access).

Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

11. INTERNATIONAL DATA TRANSFERS

FL.Inc transfers your data outside of the EEA for compliance, backup and archival purposes. We are required to store a copy of your data in Curacao for local regulatory compliance. It is only shared with the Curacao Gaming Authority on explicit request, and we will notify you within 48 hours of such a request being processed.

It is also possible that your personal information may be transferred outside of the EEA by Ad Networks, Google, or Adjust. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside the EEA.

Where we transfer your information outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to ​[email protected]

CONTACT INFORMATION

All questions, comments or enquiries should be directed to FL.inc at [email protected]​. We will endeavor to respond to any query or questions within five business days.

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Copyright (c) FreeLabs N.V. 2021

FreeLabs N.V. is registered in Curacao