PLAYMINT
Privacy Policy

PLAYMINT PTE. LTD. ("PLAYMINT", "we", "us", "our") provides interactive social games. PLAYMINT respects and values your privacy. This Privacy Policy (or "Privacy Notice") is designed to help the individuals engaging with us from the United States understand how we collect, use, process, and share your personal information, and to inform you of how to exercise your privacy rights.

Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act and California Privacy Rights Act of 2020 ("CCPA/CPRA"), please see Annex A – Supplemental CCPA/CPRA Privacy Notice.

Scope. This Privacy Notice applies to personal information processed by us, including on our websites, games, applications (including, but not limited to Solitaire Clash Classic, Mahjong Tiledom: Relaxing Match) and all other online or offline products, services, and offerings we may provide in the future. To make this Privacy Notice easier to read, our websites, mobile applications, games, and other offerings are collectively called the "Services."

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we'll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Account Creation. To access certain parts of our Services, you may need to create a profile (your "PLAYMINT Account"). When you create an PLAYMINT Account for use with our Services, we may collect username, password, country location, and email address. You may also have the option to add a short description about yourself or a profile image, your username, country location, profile image, and description about yourself, which will be visible to other Users.

• You can also access some of our Services as a guest, without creating an PLAYMINT Account. If you use our Services without creating or logging into an PLAYMINT Account, we will still collect the personal data described in "Information Collected Automatically" below associated with your device identifiers and may also collect include your name and payment information (as described in the "Payment Information" section immediately below), device information, and location. We may connect this information with your PLAYMINT Account, if you have one, or if you create an PLAYMINT Account at a later date.
• Date of Birth: to play cash games, you will need to provide your date of birth, which will be associated with your account.

Payment and Financial Account Information. This may includes bank account, payment card details, and other payment information associated with a transaction made by you in respect of our services, details about payments to and from you and other details of products and services you have purchased from us and any refunds made by you, and details of the third-party payment system you use. We use this information to process your purchases, refunds and other financial transaction requests in our Games, Products and Services. We may also process certain information to identify and prevent fraud or other illegal activities.

Your Communications with Us. We and our service providers may collect personal information, such as email address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.

Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). PLAYMINT also may collect, use, store, transmit and publicly display statistical data regarding your game play (e.g., scores, rankings, and achievements). Any information you provide using the public sharing features of the Services (referred to in this Policy as "User Content") will be considered "public," unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution and discretion before revealing any information that may identify you in the real world to other users.

Sweepstakes, Tournaments, Competitions, Contests, or other Events. We may collect personal information you provide for any sweepstakes, tournaments, competitions, contests, or other events that we offer (e.g., name, email address, date of birth). In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address or precise geo-location information if enabled on your mobile device).

Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit or emails that you open from us, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.

• Telemetry. When you play our games, we may collect statistics and other information about how you use the Services. This may include information about gameplay, game server usage, game device usage, system interactions, friends you connect with through our Services, and other information associated with your PLAYMINT Account. We might also record your gameplay, (including your button inputs), to improve our Services and prevent fraud. We may also use records of your in-game behavior and skill levels to match you with other players or the recorded gameplay of other player(s).
• Crash Reports. We may collect usage details about when you launch our games, when and how long you play each game, and detailed crash reports, which may contain information about the hardware or device you play our games on.

Cookies and Other Technologies

We, as well as third parties, may use cookies, pixel tags, and other tracking technologies ("Technologies") to automatically collect personal information through your use of the Services.

• Cookies. Cookies are small text files stored in device browsers.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies on our Services fall into the following general categories:

• Site Operations. These Technologies are used to provide Services functionality, for security and fraud prevention services, and other purposes we deem necessary to provide and maintain the Services.
• Analytics. These Technologies are used to assess the performance of our Services, and to collect analytics about use of the Services.
• Functionality. These Technologies are used to offer functionality on our Services, such as to identify you when you sign in or to keep track of your specified preferences, interests, or past items viewed.
• Sale, Sharing and Targeted Advertising. These Technologies are used for targeted advertising, and to deliver content, including ads tailored to your interests on our Services or on third-party websites and services. Some of these Technologies may involve a "sale" or "sharing" (for targeted advertising) in some jurisdictions.

See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.

3. Personal Information Collected from Third Party Sources

Third-Party Websites, Applications, or Platforms

To access some of our Services, you may have the option to link an account on a third-party website, application, or platform, such as Google, Facebook, and Apple ("Third-Party Platforms") with the Services. Third-Party Platforms are not controlled by us, and their collection and usage of personal data is subject to their respective privacy policies. We may obtain additional information about you from the Third-Party Platforms, depending on your privacy settings.

Referrals and Sharing Features

Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information with people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:

• Managing your information;
• Providing access to certain areas, functionalities, and features of the Services;
• Personalizing the Services for you, such as sending you other benefits;
• Answering requests for support;
• Communicating with you;
• Sharing personal information with third parties as needed to provide the Services;
• Processing your financial information and other payment methods for products and Services, if applicable;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Determining your eligibility to use our Services, including under local law;
• Carrying out analytics;
• Measuring interest and engagement in the Services;
• Improving, upgrading, or enhancing the Services;
• Developing new products and services;
• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
• Debugging to identify and repair errors with the Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

We may engage third-party advertising partners to promote our Services based on your interactions with our Services. Under certain state privacy laws (such as those in California, Colorado, and Virginia), this activity may be considered a 'sale' or 'sharing' of personal information, or 'targeted advertising'.

If you have any questions about our marketing practices, you may contact us at any time as set forth in "Contact Us" below.

D. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

E. Automated Decision Making

We may engage in automated decision making, including profiling, such as to determine your skill level to match you with difficulty game level. Our processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making.

If you have questions about our automated decision making, you may contact us as set forth in "Contact Us" below.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

1. Disclosures to Provide the Services

We may disclose any of the personal information we collect to the categories of third parties described below. These third parties may be located in the USA or other countries.

Service Providers

We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.

Some of the service providers we may use include:

• Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics' Privacy Policy. To learn more about how to opt-out of Google Analytics' use of your personal information, please click here.

Other Users You Share or Interact With

The Services may allow our users to share personal information or interact with other users of the Services, such as your profile or User Content (which may be viewed by other users).

Third-Party Services You Share or Interact With

The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a "Third-Party Service").

Any personal information shared with a Third-Party Service will be subject to the Third-Party Service's privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

Business Partners

We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Once your personal information is shared with our business partner, it will also be subject to our business partner's privacy policy. We are not responsible for the processing of personal information by our business partners.

Affiliates

We may share your personal information with our corporate affiliates.

Advertising Partners

We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising", "personalized advertising", or "targeted advertising."

2. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties:

• if we are required to do so to comply with our legal or regulatory requirements; or
• if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

3. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices

The privacy choices you may have about your personal information are described below.

Email Communications

If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).

Mobile Devices

We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

"Do Not Track"

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Technologies

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.

When you visit a website we operate, where required under the applicable law, we will provide mechanisms that allow you to opt out of Technologies as required by applicable law.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights

In accordance with applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information;
• Request Access to or Portability of Your Personal Information;
• Request Correction of your personal information;
• Request Deletion of your personal information;
• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for "targeted advertising" (as "targeted advertising" is defined by applicable privacy laws), if we "sell" your personal information (as "sell" is defined by applicable privacy laws), or if we engage in "profiling" in furtherance of certain "decisions that produce legal or similarly significant effects" concerning you (as such terms are defined by applicable privacy laws); and
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in "Contact Us" below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to provide or confirm additional information, such as your name, email address and/or the unique identifier number (UID) associated with your account.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

If you would like to exercise any of these rights, please contact us as set forth in "Contact Us" below.

To opt out of the following activities under applicable privacy laws:

• Sale of personal information (as defined by laws such as the CCPA/CPRA);
• Sharing of personal information for cross-context behavioral advertising (as defined by laws such as the CCPA/CPRA);
• Targeted advertising (as defined by laws such as Colorado Privacy Act (CPA) and Virginia Consumer Data Protection Act (VCDPA);

You may also contact us as set forth in "Contact Us" below.

We will process such requests in accordance with applicable laws.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. CHILDREN'S INFORMATION

Our Services are designed for a general audience above 13 years old. We do not intend to or knowingly collect personal data from children under the age of 13. If a child under the age of 13 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If you believe that we might have any information from or about children under the age of 13, please contact us as described in "Contact Us" below.

If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child's PLAYMINT Account, if applicable.

9. OTHER PROVISIONS

Sensitive Personal Information

We do not generally require you to disclose any sensitive personal information (for example, details of race, religious belief, or sexual orientation) to us, unless we have a legitimate ground to do so, such as it is necessary for us to provide the Services, perform a contract with you, or fulfill a legal obligation. If you do provide us with sensitive personal information for any reason, you consent to us collecting that information and then using and disclosing that information for the purpose for which you disclosed it to us.

Third-Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services or the Services may allow you to interact with third-party services that are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the third-party's actions or omissions, including but not limited to their privacy practices, content of such other websites or applications, and errors or bugs in their software. Providing personal information to third-party websites or applications is at your own risk.

10. CONTACT US

PLAYMINT PTE. LTD. is the controller of the personal information we process under this Privacy Notice.