Last updated December 14, 2023

This privacy notice for INFIPLAY INC. LIMITED ('Company', 'we', 'us', or 'our',), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services’, ‘Games”), such as when you:

▪       Visit our website at https://infiplay.com/, or any website of ours that links to this privacy notice;

▪       Use our games and mobile applications;

▪       Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at acc@infiplay.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with INFIPLAY INC. LIMITED and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We may process sensitive personal information, when necessary, with your consent or as otherwise permitted by applicable law.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. DO WE COLLECT INFORMATION FROM MINORS?

10. WHAT ARE YOUR PRIVACY RIGHTS?

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

▪       names

▪       phone numbers

▪       email addresses

▪       mailing addresses

▪       usernames

▪       passwords

▪       contact or authentication data

▪       billing addresses

▪       debit/credit card numbers

▪       contact preferences

▪       payment history on infiplay.com and in-app purchases in the Games

▪       Phone number, First name, Second name, Middle name, Birth date (Only in case of additional clear consent of the User and only for the purposes of additional personal technical support provided for the User by the Company)

▪       Login

▪       Password

▪       Social network ID

▪       Information about the resource from which the User came to the Company's website or other site where the Company's Games are placed

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

▪       financial data

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

The User agrees that the Company, as it oversees the Games, also receives some information of a technical/in-game nature, among which is information about the User's activity within the game, including:

     (a) information about logging in to a Game (time and quantity of logins);

     (b) in-game locations visited by the User while using a Game;

     (c) items purchased while using a Game;

     (d) items sold while using a Game;

     (e) missions (tasks) the User accepts as assignments to complete;

     (f) missions (tasks) the User completes;

     (g) the number of gaming actions performed by the User with other Users;

     (h) the number of invitations sent by the User to other Users;

     (i) the amount of virtual game currency owned by the User;

     (j) the amount of virtual game currency earned/purchased by the User;

     (k) Information about approximate time spent in game;

     (l) Character information (server, name, level).

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

The information we collect includes:

▪       Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

▪       Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

▪       Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In the course of providing our services, we may require you to enable certain device access permissions depending on the specific scenario and feature of the service. You can choose whether or not to allow us to use the relevant permissions on your device. If you do not authorize us to use the relevant permissions, some products/services may not be available, but this will not affect your access to the main functions and other features of the relevant products/services.

With your consent, we will access your device's camera, photo album (photo gallery), microphone, geolocation and other permissions to enable the collection and use of information related to functions such as camera shooting, scanning codes, uploading pictures, voice calls, provision of appropriate services based on location, and so on. For example, when you want to interact with other gamers through images, voice or video and participate in live broadcasts, with your authorized consent, we will access your photos or saved files, microphone, camera and geolocation in order to provide you with features such as saving screenshots, uploading images, voice chat, finding nearby gamers to interact with, etc. Please note that by enabling these permissions, you are giving us permission to collect and use this personal information to perform the functions described above, and by disabling these permissions, you are revoking these permissions, and we will no longer be able to collect and use your personal information or provide you with features that comply with these permissions. Your decision to disable these permissions will not affect the processing of personal information that was previously based on your permission. You can also disable some or all of the permissions at any time in your device's settings feature, thereby revoking the consent you have given us for a particular permission. The method for displaying and disabling permissions may vary from device to device, see device and system developer's instructions or guides for details. For Android and iOS users, our use of permissions can be found in the list of system permissions.

Please note: when you use a device with a depth camera function (such as iPhone phones, some Android devices) and agree to turn on the camera, you can access the AR (augmented reality) experience in our products/services. For example, we receive a small amount trait (data) of your facial expressions through the TrueDepth API and map them to your in-game character to ensure that the character’s expressions, makeup, etc. are in sync, and we do not compile any personal data during this process.

While using our AR experience

     • We do not have access to your personal information (including Face ID) through your device's own depth camera function. The values (data) we get through the TrueDepth API do not identify anyone.

     • All data we receive through your device's depth camera function (e.g. via the TrueDepth API) is deleted instantly, not stored in any way (including in any cache, cloud storage, etc.), not shared or distributed to any third parties.

     • You can stop using your device's camera at any time using the toggle switch in settings.

To avoid any doubt, when you are projecting an image of your character, a virtual stage, etc. onto a realistic scene that your camera may be capturing, you do not need to press the capture button and we do not collect any personal information from you in the process.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU, Malaysia, Singapore or UK, this section applies to you.

The General Data Protection Regulation (GDPR), Personal Data Protection Act (“PDPA”), UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

▪       Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

▪       Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

▪       Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

▪       Send users information about special offers and discounts on our products and services

▪       Develop and display personalised and relevant advertising content for our users

▪       Analyse how our Services are used so we can improve them to engage and retain users

▪       Support our marketing activities

▪       Diagnose problems and/or prevent fraudulent activities

▪       Understand how our users use our products and services so we can improve user experience

▪       Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

▪       Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

▪       If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

▪       For investigations and fraud detection and prevention

▪       For business transactions provided certain conditions are met

▪       If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

▪       For identifying injured, ill, or deceased persons and communicating with next of kin

▪       If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

▪       If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

▪       If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

▪       If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

▪       If the collection is solely for journalistic, artistic, or literary purposes

▪       If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

▪       Ad Networks

▪       Affiliate Marketing Programs

▪       Cloud Computing Services

▪       Communication & Collaboration Tools

▪       Data Analytics Services

▪       Data Storage Service Providers

▪       Finance & Accounting Tools

▪       Payment Processors

▪       Performance Monitoring Tools

▪       Retargeting Platforms

▪       Sales & Marketing Tools

▪       Testing Tools

▪       Social Networks

▪       Order Fulfilment Service Providers

▪       Product Engineering & Design Tools

▪       User Account Registration & Authentication Services

▪       Website Hosting Service Providers

We also may need to share your personal information in the following situations:

With our partners who help us support the App:

We may have partners that help us to make the App better, including analytics and advertising services which may process your Personal Data for purposes specified in section “HOW DO WE PROCESS YOUR PERSONAL DATA?” above respectively.

A list of third-party services used by App is below.

Analytics services. We may use third-party service providers to monitor and analyze the use of our App, as follows:

• Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Privacy Help Center, Privacy Policy of Google Inc.
• Google Firebase. Google Firebase is a mobile and web app development platform that offers several integrated features such as a mobile app server, analytics tools, app promotion and monetization tools provided by Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Privacy Help Center,Privacy Policy of Firebase.

• AppsFlyer. AppsFlyer is a mobile marketing analytics and attribution platform provided by AppsFlyer. Address: to the attention of Legal Team/Data Protection Officer, 14 Maskit St., Herzliya, Israel, 4673314. privacy@appsflyer.com, Privacy Policy of AppsFlyer.

Ads systems. We may use third-party service providers advertising purposes respectively, as follows:

• Facebook Ads. Facebook Ads Manager is a Facebook tool that allows to create and manage ads provided by Meta Platforms, Inc. Address: 1601 Willow Road, Menlo Park, CA 94025, USA. Privacy Policy of Meta.

• Google Ads. Google Ads is a contextual advertising service from Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Privacy Help Center, Privacy Policy of Google, Inc.
• Apple Search Ads. Apple Search Ads makes us easy to manage our ads campaigns. Service is provided by Apple, Inc. Address: Apple Park Way, Cupertino, CA 95014, United States. Privacy Enquiries,Privacy Policy of Apple, Inc.
• TIK TOK Ads. TIK TOK Ads is an advertising service. Transfer to the USA, the Russian Federation, the UAE, Indonesia, India based on the Jurisdiction Specific Termsand Controller to Controller Data Terms,Request privacy information.

Other partners. We also have partners to help us maintain the App:

• Hetzner Online GmbH. Hetzner Online GmbH is a cloud hosting provider that offers cloud computing services and infrastructure as a service. Address: Industriestr. 25, 91710 Gunzenhausen, Germany. data-protection@hetzner.com,Privacy Policy of Hetzner Online GmbH.
• SERVERS.COM INC. SERVERS.COM INC is a cloud hosting provider that offers cloud computing services and infrastructure as a service. Address: 2777 N STEMMONS FWY., SUITE 1655, DALLAS, TX 75207, USA. privacy@servers.com,Privacy Policy of SERVERS.COM INC.
• ACEVILLE PTE.LTD. ACEVILLE PTE.LTD. is a cloud hosting provider that offers cloud computing services and infrastructure as a service. Address: 30 RAFFLES PLACE, 12 01, OXLEY RAFFLES, SINGAPORE 048622. cloudlegalnotices@tencent.com,Privacy Policy of ACEVILLE PTE.LTD.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than thirty-six (36) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at acc@infiplay.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  You may review, change, or terminate your account at any time.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

▪       Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at acc@infiplay.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at acc@infiplay.com or by post to:

INFIPLAY INC. LIMITED

UNIT A 3/F CHEONG SUN TOWER 116-118 WING LOK ST SHEUNG WAN HONGKONG

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit an e-mail to acc@infiplay.com.