PRIVACY POLICY

Last Updated: January 27, 2021

This Privacy Policy explains how information about you is collected, used and disclosed by POMELO Entertainment Inc., (“PEI”, “us”, “we” or “our”) when you use our websites, mobile applications and services that contain this policy (collectively, the “Services”) or when you otherwise interact with us. PEI is the data controller of your personal information for purposes of the EU General Data Protection Regulation.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as by adding a statement to the homepage of our Services or sending you a notification). If you do not agree to the changes, please do not use our Services or otherwise provide us with your personal information.  We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

I.                    Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, interact with other users, request customer support, sign up to receive newsletters, participate in surveys or otherwise communicate with us. The types of information we may collect include your username, password, email address, photos, and any other information you choose to provide.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect information about you, including:

·         Usage Information: We collect information about your use of our Services, including gaming service ID, levels completed, game scores, time spent using our Services, and other game play information.

·         Log Information: We log information about your use of our Services, including your browser type and language, access times, pages viewed, your IP address and the website you visited before navigating to our Services.

·         Hardware Information: We collect information about the computer or device you use to access our Services, including the hardware model, operating system and version, browser  mobile network information,  MAC address, IP address International Mobile Equipment Identity (“IMEI”) number and other unique device identifiers made available by the operating system of your device.

·         Location Information: We may collect information regarding the geographic location of your device each time you use the Services provided on iOS or Android platforms, or otherwise consent to the collection of this information. You may opt-out of the collection of platform provided location data using the settings on your device. Your location is stored for the period specified in the Services before collection.

 Information We Collect From Other Sources

We may also obtain information from other sources as far as it is necessary to perform our Services, and combine that with information we collect through our Services. For instance, we may collect game ranking and achievement status from your console or mobile operating system game center application. Additionally, when you complete in-app purchases, we may collect information about you from the provider of your device operating system when they process the purchases on our behalf. Please note that we do not receive your payment method information from the operating system providers. In all other cases we will ask you to authorize us to collect, store, and use personal information from third parties.

II.                 Use of Information

We only collect, store and use your information if you have consented to it or, to the extent that it is necessary (i) for the performance of your agreement with us; (ii) to comply with our legal obligations; or (iii) for the purpose of our legitimate interests, including operating, evaluating and improving our global business. We have carefully balanced our legitimate business interests against your data protection rights. Please contact us using the contact details provided below if you have questions on this balancing of interests.

We (or a third party data processor on our behalf) may collect, store and use information about you for the following purposes for the periods necessary to achieve such purposes:

·         Provide, maintain and improve our Services;

·         Provide and deliver the products and services you request, process transactions and send you related information;

·         Register you for an account on our Services and assist in the management of your account

·         Respond to your comments, questions and requests and provide customer service;

·         Send you technical notices, updates, security alerts and support and administrative messages;

·         Monitor and analyze trends, usage and activities in connection with our Services;

·         Process and deliver contest entries and rewards promoted by PEI;

·         Personalize and improve the Services and provide in-Service advertisements, content or features that match user profiles or interests;

·         Link or combine with information we get from others to help understand your needs and provide you with better service;

·         Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity;

·         For any other purpose required or authorized for us to comply with our legal and regulatory obligations; and

·         For any other purpose for which you provided the information.

III.               Sharing of Information

We do not share, transfer or otherwise exchange your personal information with third parties, unless required for the provision of our products or services, otherwise in accordance with this Privacy Policy, as permitted by law, or if you have given us express consent. We do not sell your personal information to third parties. In compliance with the aforementioned, we may share information about you as follows or as otherwise described in this Privacy Policy:

·         With other users if you choose to participate in the interactive areas of our Services, such as multiplayer, chat, or sharing features (the use of personally identifiable data (such as your full name) as a username in our services is strictly prohibited);

·         With our employees, affiliates, related companies, vendors, consultants and other third party service providers who need access to such information to carry out work on our behalf (including, for example, developers, payment processors, website hosting services, or information storage and processing service providers);

·         In response to legal process or a request for information if disclosure is in accordance with, or as otherwise required by, any applicable law, rule, or regulation (including, for example government or regulatory bodies, law enforcement, or courts of law);

·         If we have reasonable grounds to believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of PEI, our users or others;

·         In connection with any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and

·         With your consent or at your direction.

IV.                Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services on our behalf and to serve advertisements within our Services.  These entities may use technologies to automatically collect information about your device and your use of our Services, including IP address, device ID, time spent on pages within our Services, and links clicked within our Services.  This information may be used by us and others to, among other things, maintain, improve, and analyze the functioning of our Services and deliver contextual or targeted advertising that may be of interest to you. The use of your information by these third parties is covered by their respective privacy policies, and we do not control and are not responsible for the privacy practices of third parties.

Some of our Services will, with your prior consent, combine game play and analytic information with information collected from other POMELO Entertainment games, games from our group companies, and other third party sources to analyze game and monetization trends, create profiles of categories of players, create new games and services, and perform other analytics. We also use certain information collected through our games for advertisement targeting outside of the game. This includes creating profiles of types of players by combining your data with information from our advertising partners, providing the data to our ad agencies and ad platforms to target advertisements of our (and our group company) games and services to you outside of this game, and otherwise performing advertising analytics and performance metrics.

V.                  Social Sharing Feature

The Services may offer social sharing features or other tools, which let you share actions or link the Services with social media.  The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social media platform.  For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the social media platforms.

VI.               Security

We take reasonable technical and organizational measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no transmission over the internet can ever be guaranteed secure so we cannot guarantee the security of any personal information that you transfer over the internet to us.

VII.             Storing and deleting data

Personal information collected through the Services is being stored and deleted in compliance with privacy requirements. All data will be de-identified or deleted if no longer required for the purposes mentioned above, unless further retention is required by law. 

VIII.          Third Party Sites

Our Services may contain links to other websites  or services operated by third parties.  Please note that this Privacy Policy applies only to our Services and we cannot be responsible for personal information that third parties may collect, store and use through their website.  You should always read the privacy policy of each website you visit carefully.

IX.                  Push Notifications/Alerts

PEI may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device. PEI will send push notifications or alerts with promotional content only after your prior opt-in to receiving such messages on your device.

X.      Contact

If you have any questions about this Privacy Policy or our practices, please contact us at:

POMELO Entertainment Inc.

privacycontact@pomeloent.com