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PRIVACY POLICY

Last Updated: September, 2024

PLAYSIMPLE GAMES PRIVATE LIMITED

Playsimple Games Private Limited (“Playsimple,” “we,” “us,” or “our”) is dedicated to protecting the privacy rights of our Users (“User,” “your,” or “you”) whose information is collected, processed, and stored while using our Platforms. This Privacy Policy (the “Privacy Policy”) describes how we collect, store, use, disclose, safeguard, and manage your data, including data that you provide or we collect when you use our gaming platforms (individually the “Platform” and collectively the “Platforms”) through our Website at http://playsimple.in/ (the “Website”) or through our mobile applications (“App” when it is a single gaming application and “Apps” for multiple gaming applications) (collectively, the “Services”). The capitalized terms have the same meaning as ascribed in our Terms of Service, as applicable, unless otherwise noted here.

The meaning of certain terms used in this Privacy Policy are defined by the General Data Protection Regulation (“GDPR”), unless otherwise stated. When we refer to the GDPR we are referring to the General Data Protection Regulation of the UK as well, unless we otherwise specify. All definitions set out in Art. 4 of the GDPR apply to this Privacy Policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR PERSONAL DATA AND HOW WE TREAT IT.IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT [email protected]. IF APPLICABLE, YOU SHALL HAVE THE OPTION AT ANY TIME TO WITHDRAW YOUR CONSENT TO COLLECT, STORE, AND/OR PROCESS YOUR PERSONAL INFORMATION.SUCH WITHDRAWAL OF CONSENT SHOULD BE SENT TO US THROUGH OUR APP OR VIA EMAIL TO dat [email protected]

This Privacy Policy may be updated from time to time, therefore it is advisable to review it frequently. We will notify you of material changes to this Privacy Policy via a notice on our home page (http://playsimple.in/). Your continued use of our Platform or Services means that you accept any changes made. If you disagree with the processing of data described in this Privacy Policy, you may not be able to continue to use the Platforms or Services provided.

WHO WE ARE

We are the controller of your personal data when processing it:

Playsimple Games Private Limited

No 147, 2nd floor, Anjaneya Techno Park Kodihalli

HAL Old Airport Road - Bangalore , Karnataka - 560 008

We work together with our affiliate company (“Affiliate”):

PlaySimple Games Pte. Ltd.,

30, Cecil Street, #19-08, Prudential Towers,

Singapore, 049712

Together we are the PlaySimple Group, a group of undertakings (“PlaySimple Group”).

If you want to contact us in regards to any data protection request, we encourage you to use the “Contact us” option available in the game(s). Alternatively, you can reach out to our Data Protection Officer at any time by sending an email to [email protected]

We and our Affiliate have a representative in the European Union for data protection matters:

Modern Times Group MTG AB,

556309-9158, Skeppsbron 18,

Box 2094, 111 30 Stockholm, Sweden

Since we and our Affiliate are subsidiary companies of Modern Times Group MTG AB (“MTG”), we and our Affiliate form a group of undertakings together with it and its other subsidiaries.

TERRITORIAL RESTRICTION

If you are a resident of the United States (“US”), the laws of the State of Delaware, United States shall apply. If you are a resident of any other country, please ensure compliance with all local laws prior to using our Website, App, or Platform. You must comply with our Terms of Use and Terms of Service, as applicable.

Some terms we use in this Privacy Policy are defined by the General Data Protection Regulation (“GDPR”), a data protection law of the European Union. Unless we specify otherwise, when we refer to the GDPR we are referring to the UK General Data Protection Regulation as well since both laws are very similar.Art. 4 of the GDPR gives detailed definitions of the terms we apply in this Privacy Policy.

WHAT DATA DO WE COLLECT?

The types of data we collect depend on the Services you use, and the applicable laws.

Data provided by you

Player name (real or alias)
Contact information (name, email address,phone number)
Profile information (such as profile photo)
Your in-game messages (e.g., your support tickets and chat logs)
Other information you choose to share (e.g., data to identify your lost account)

Data collected automatically

Your game account details and game progress
Your Mobile device identifiers and IP address
Your device data (e.g., the device name, operating system, and language)
Data we collect using cookies and similar technologies (see more below)
Approximate location (as suggested by your IP address)
Your gameplay data and/or interactions with other players inside the Service
Application performance and debugging information

Data collected from our partners

We also use third-party partners, such as social networking sites, advertising networks, and data analytics providers.

Data made available by you via your privacy settings in third-party services like Facebook, Google and Apple
Demographic data (e.g.,to determine the approximate location of your IP address)
Data to fight fraud related to refunds or advertising
Data from the platforms that the games run on (such as purchase data for verifying payments)
Additional information (e.g., advertising and analytics data) to improve the relevance of our ads and services we provide

WHY DO WE COLLECT YOUR DATA

You personal data maybe processed for the following purposes:

Offer our Services

To create accounts and make our Service available to you
Verify and confirm payments
Process your requests

A contract between you and us or our Affiliate can be used to offer you our Services. The basis for processing your personal data is our legitimate interest to offer you our Services (Art. 6 (1)(b) and/or (f) of the GDPR).

Without this data we would not be able to enter into, or fulfill our obligations under, a contract with you.

Offering Additional Services

Maintain and update player profiles
Enable social features in our Services
Enable personalization and customization in our Services
Provide player support
Provide offers within our Services
Communicate with you regarding service updates, security alerts, and support messages
Enable communication within the player community

Offering Additional Services is based on the legitimate interest of ours and our Affiliate to offer you interesting features and a good user experience. Due to this, the legal basis for processing your data is Art. 6(1)(f) of the GDPR.

Show personalized advertisements

Make advertisements more relevant to you
Serve, measure and improve the effectiveness of advertising

Processing your personal data to show personalized advertisements,Data disclosure will be conducted and measure and improve their effectiveness, is based on your consent. The legal basis for processing this data is Art. 6(1)(a) of the GDPR. For information on how to opt-out of personalized advertisements, see section 'Your Rights and Options' below.

Provide a safe, fair experience and take legal matters into account

We strive to maintain the highest standard of safety and fairness in all our features. To maintain these standards and fight fraud, we use the data to

Analyze and monitor the social features
Take action against any fraudulent activity
Verify your identity, if needed, to comply with your data subject requests
Maintain proof of our compliance with applicable laws (e.g., the GDPR)
Sufficiently defend ourselves against any legal claims

Ensuring that our Services are safe and fair is a legitimate interest of ours and our Affiliate, enabling us to offer interesting features and a good user experience. This includes complying with applicable laws and being able to sufficiently defend ourselves and our Affiliate against legal claims, given this can have legally binding effects on us as a company. The legal basis for processing your data is Art. 6(1)(f) of the GDPR. Additionally, the processing of your personal data for verification purposes, compliance or legal defense is based on Art. 6(1)(c) of the GDPR, since we can be obliged by law to process the data.

For details on our policies and terms of service, please visit here.

WHO CAN SEE YOUR DATA?

Apart from PlaySimple, some of your data may be available to others in the following situations:

OTHER PLAYERS

Through our Social features, other players may be able to view your profile, in-game achievements and any other details that you made public. If you share personal information, post an image or video, or provide other content in public forums (such as on message boards, leaderboards, in chat rooms, comment fields, or on profile pages) other people can view, collect and use that information. If your user name or ID contains your real name, then you acknowledge that your name will be made publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of such public forums may then be able to identify you, use the information to send you messages, or copy any of the images, video or content you have shared. You are strongly encouraged not to share your personal information in public forums or in your username or ID. You are responsible for any information or content you publicly post using our Services.

SERVICE PROVIDERS & AFFILIATES

We work together with vendors who can process personal data we share with them to provide certain services, including hosting, player support, advertising, analytics and fraud prevention.

Our partners provide our Service with features, such as social media interaction tools,application programming interfaces (APIs) or software development kits (SDKs) and in-game advertising. These partners operate under their own privacy policies, thus we encourage you to check their privacy policies and data processing practices.

The data collected by these partners may include your IP address, mobile identifiers, page(s) visited, location and time of day. This data may be combined with the data we have collected from you. Together, this data may be used for targeted advertisements when you visit third-party services within their networks. If you do not want to share your personal data with third-party advertising partners, please follow the instructions given under the “Your Rights and Options” section below.

Our partners provide certain features to our Service, such as social media interaction tools, application programming interfaces (APIs) or software development kits (SDKs) and in-game advertising. These partners operate under their own privacy policies hence we encourage you to check their privacy policies and data processing practices.

OTHER COMPANIES AND AUTHORITIES

In case of any fraud or illegal activity, your data may be shared with other organizations and/or public authorities in response to lawful requests.Data disclosure will be conducted in accordance with the law and protection of the rights and safety of our players shall be ensured.

INTERNATIONAL DATA TRANSFERS

If you are an EU resident, we rely on certain safeguards when sharing your personal data with a recipient established outside of the EEA/EU.

Some vendors we share your personal data with are well established outside the European Union. There are two principal safeguards we rely on when we sharing your personal data with these recipients:

If a recipient is located in a country which the European Commission has found provides an adequate level of data protection, we rely on such adequacy decisions by the EU Commission.
If a recipient is located in a country without an adequate level of data protection

according to the European Commission, we have either concluded a contract with this recipient where we agreed upon rules to ensure the recipient takes adequate care of your personal data (EU Standard Contractual Clauses developed by the European Commission) or we rely on binding corporate rules of a group of undertakings or enterprises which have been approved by a supervisory authority.

YOUR RIGHTS AND OPTIONS

Push Notifications

You may opt-out from receiving our push-notifications by changing the settings on your mobile device.

Opt-out of targeted advertising

You can opt-out of interest-based advertising by following the privacy settings of your Android, iOS or Amazon device and selecting "Limit Ad Tracking." You can also opt-out by turning off “personalized ads” on Apple iOS, "Opt-out of Interest Based Ads" on Android or by disabling Interest based Ads on Amazon.

You can choose to agree or disagree with the sharing of your personal data to receive targeted ads:

iOS: Choose from the consent pop-up at the start of the game (if you haven’t already generally disabled tracking in your system settings).
Android: Opt out of ad tracking by going to Settings > Ads > Opt out of Ads Personalization
Fire OS: Opt out of ad tracking by going to Settings > Security & Privacy > Advertising ID > Interest-Based Ads

If you would like more information about our advertising practices and your ability to prevent these companies from receiving your information, you can visit Apple/Google's Advertising and Privacy page or the Network Advertising Initiative. Please understand that if you disable or block certain ad features, other aspects of our mobile games may not work correctly.

Your Rights

Under the GDPR you have certain rights regarding the processing of your personal data. Under the GDPR you have the following rights:

Right of information: You have the right to be provided information regarding the processing of your personal data, in accordance with Art. 13 and 14 of the GDPR.
Right of access: You have the right to obtain confirmation as to whether we are processing your personal data, and, if this should be the case, access to that personal data in accordance with Art. 15 of the GDPR.
Right to rectification: You have the right to obtain rectification of inaccurate or incomplete personal data regarding you in accordance with Art. 16 of the GDPR.
Right to erasure (“right to be forgotten”): You have the right to obtain erasure of your personal data in accordance with Art. 17 of the GDPR.
Right to restriction: Under certain circumstances you have the right to obtain a restriction of the processing of your personal data, in accordance with Art. 18 of the GDPR.
Right to data portability: Under certain circumstances you have the right to receive the personal data you provided us, in a structured, commonly used and machine-readable format, and the right to transmit this data to another controller, in accordance with Art. 20 of the GDPR.
Right to object: Under certain circumstances you have the right to object to the processing of your personal data, in accordance with Art. 21of the UK GDPR. This includes but is not limited to the right to object in cases where we process your personal data on the legal basis of Art. 6(1)(f) of the GDPR.
Right to lodge a complaint: You have the right to lodge a complaint with a supervisory

authority, in particular in the Member State of the EU of your habitual residence, place of work or the place of the alleged infringement, if you feel the processing of your personal data violates the GDPR, as set out in Art. 77 of the GDPR. If you are in the EU, you can contact the Swedish Data Protection Authority(IMY) here.

If you are in the UK, you can contact the Information Commissioner's Office(ICO) here.

Right to withdraw consent: If the processing of your personal data is based on your consent, as set out in Art. 6(1)(a) of the GDPR or Art. 9(2)(a) of the GDPR, you may withdraw your consent at any time in accordance with Art. 7(3) of the GDPR. Such

withdrawal does not affect the lawfulness of the processing prior to its withdrawal.
Right not to be subject to a decision based solely on automated processing: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you, as set out in Art. 22(1) of the GDPR.

If you wish to exercise any of the rights mentioned below :

Right of Access/right of disclosure/right to know
Right to erasure/right to deletion (the right to be forgotten)
Right to withdraw consent

Please contact our support team through the in-game Help Center. For all your data-related requests, please follow the following steps: Contact us / Help Center > Other issue > My Data. Apart from the self-service mechanisms, the PlaySimple Group offers a channel to contact the Data Protection Team and exercise the rest of your data subject rights via email ([email protected]).

If you wish to exercise any of the rights mentioned above, please contact our support team through the in-game Help Center. For all your data related request, please follow the steps: Contact us / Help Center > Other issue > My Data

We may take additional steps to verify your identity before fulfilling your request.

COOKIES AND SIMILAR TECHNOLOGIES

Our services, and those of our partners, use cookies and similar technologies to enhance our product. Please note that our partners may operate under their own privacy policies.

We collect and store your information using cookies and similar tracking technologies in order to

Detect and prevent fraud;
Enable users to sync devices seamlessly
Carry out analytics and personalization
Limit the the number of times players are shown the same advertisement across all known or inferred devices
Show personalized advertising on each device

Google, as a third-party vendor, uses Cookies to show advertisements to Users on our Platforms,

Website, and Apps. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions on our Platforms, Website, and Apps. We currently use Google Analytics to collect and process usage data from our career website, Platforms and Apps. To learn more about Google Analytics and how to opt-out, please visit :

https://policies.google.com/privacy/google-partners.

We have implemented advertising features in our Apps and on our Platforms, including Google’s

“DoubleClick” platform integration. We use these Cookies and similar technologies to compile data concerning User interactions with ad impressions and other ad service functions.

HOW DO WE PROTECT YOUR DATA

Security Safeguards

Our priority is to provide a safe and transparent gaming environment for our players.In order to maintain this, we ensure that our security system is constantly evolving to meet the highest standard possible. We take all necessary technical and organizational measures to protect your data from unauthorized access or misuse.

Data retention

We'll keep your information for as long as necessary to provide you with the Services, fulfill our legal obligations, and/or exercise, defend or establish our rights.

If you wish to delete your account then please follow Contact us / Help Center > Other issue > My Data > Delete My Data.We will maintain your account for the length of time for which we reasonably expect you to re-engage with our Services. After such a period, we will delete your personal information, including your personal identifiable information, and you may no longer be able to access your account.

COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

The Services are not intended for use by children (aged 13 or such higher age as required by applicable law). We do not knowingly collect personal information from children through the Services or knowingly allow them to use our Services. If we learn that we have unintentionally collected personal information from a child, we will delete that information. If you believe that we might have collected personal information from or about a child, please email us at [email protected]

COPYRIGHT POLICY

The contents of this website, our Platforms, and the Apps may not be reproduced partially or fully, without due permission from Playsimple as per the Copyright Act, 1957. If referred to as a part of another publication, the source must be appropriately acknowledged. The contents of this website cannot be used in any misleading or objectionable context.

THESE TERMS ARE IN ADDITION TO THE TERMS AND CONDITIONS IN OUR

GENERIC TERMS OF USE. PLEASE READ OUR PRIVACY POLICY AND TERMS OF USE. BY REGISTERING ON OUR WEBSITE TO PLAY OUR GAMES AND/OR BY PLAYING OUR GAMES, YOU AGREE TO THE TERMS AND CONDITIONS IN OUR

PRIVACY POLICY, TERMS OF USE, AND THE APPLICABLE SPECIFIC USER TERMS OF USE. READ ALL TERMS CAREFULLY. IF YOU DO NOT WANT TO BE BOUND BY OUR TERMS AND CONDITIONS, DO NOT REGISTER OR PLAY OUR GAMES. YOU

ARE ALSO BOUND BY THE TERMS AND CONDITIONS AND PRIVACY POLICIES OF OUR PARTNERS, WHOSE GAMES ARE FOUND ON OR ASSOCIATED WITH OUR WEB SITE.

FOR CALIFORNIA RESIDENTS

Please visit playsimple.in/disclosure-california-residents for special disclosures pertaining to California residents

FOR CANADIAN USERS

Please visit playsimple.in/disclosure-canada-residents for special disclosures pertaining to Canada residents

PLEASE NOTE: IF YOU USE AND NAVIGATE THROUGH OUR PLATFORMS OR OUR WEBSITE AND/OR DOWNLOAD OR USE OUR APPS, OR ACCESS OUR PLATFORMS OR USE OUR SERVICES, YOU HAVE AGREED TO AND ACCEPTED THE TERMS AND PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE. IF YOU DO

NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE, PLEASE DO NOT