Introduction

GINGER JOY LIMITED ("Ginger Joy" or "we", "us", "our") is a technology company that develops blockchain based mobile applications. With this Privacy Policy, we aim to explain how and why we gather, store, share and use your personal data in a manner consistent with the laws of the countries where we do business.

Where we decide the means or purpose of processing your personal data, we are the “controller."

This notice explains how we process personal data, as a controller, relating to:

• Visitors (“Website Users”) to our website: .com (“Website”)
• Users (“Mobile App Users”) of our mobile applications (“Apps”), which are accessible via certain online stores such as Google Play Store and Apple App Store.

Together the Website Users and Mobile App Users shall be the “Users” (and “you” and “your” shall refer to any User).

We update this notice from time to time, so Users should check back in on a regular basis.

Please refer to the privacy notices of the websites or services mentioned here to understand how they process personal data.

Personal Data and How We Use It

• Our Purpose

We collect and use your personal data for the following purposes:

• We gather and utilise your personal information for the following reasons:
• To deliver our Apps, ensuring purchases are activated, and provide player support
• To operate, improve, and optimise Apps,
• To manage the organization's day-to-day operations,
• To optimise Apps for users and devices, and deliver customised in-game events, offers, and promotions,
• To verify identity and entitlement to products or services,
• To assist in maintaining the safety, security, and integrity of property, services, technology assets, and business,
• To personalise services, understand users and preferences, enhance user experience and enjoyment, and
• To communicate Apps-related information, such as confirmations, technical notices, updates, security alerts, support, and administrative messages,
• To prevent potentially prohibited or illegal activities, such as cheating or fraud, and to protect players,
• To ensure internal quality control,
• To comply with contractual and legal obligations and requirements,
• As otherwise expressly set out in this Privacy Policy or as required or permitted by law.
• Categories of Personal Data

We collect and process following data categories:

• Marketing

We utilise information about you to ensure that you only see marketing from us that is relevant to you. This includes using information about you that we will have, such as:

• ad identifiers and other non-personal information collected from your device;
• the games you play and information about how you interact with our games and Services; your age, country or region, and gender; and
• Mobile App Users’ IDFA (identifier for advertisers) and/or AAID (advertising-related identifying data) and
• other information that we might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
• Advertising

Our Apps will include advertising for third party products and services.

We and our advertising partners collect and use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our Apps.

We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our Apps that might be of interest to you. This includes information such as:

• ad identifiers and other information collected from your device.
• the games you play and information about how you interact with our games and Services; your age, country and region, and gender; and
• other demographic and interests based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
• Analytics

We process each Mobile App User’s device’s operating system, resolution settings, language settings, time zone settings and IP address; as well as the version of the App downloaded to each Mobile App User’s device.

• Gameplay

We process certain information such as users’ in-app purchase history, subscription data, player progress, IP-based location, Apple ID, Facebook ID and Facebook name.

• Cookies Analytics and Similar Technologies

We use ad identifiers, cookies and similar technologies. Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

• Legal Bases

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. The legal bases which we rely upon are the following:

• Contractual Necessity. This covers data used by us in order to provide you with services that you have requested - and that we have agreed - to provide to you, such as our Apps, customer services, chat functionality and third-party social network connectivity;
• Legal Obligation. This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data;
• Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our services, such as marketing, advertising, analytics, research and optimization of our Apps; and
• Consent. This is used as a legal basis in the following contexts: the collection of data stored on your device by our advertising partners and us, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and can withdraw your consent by uninstalling our Apps.

Storage, Transfers and Disclosure

• Security

We adhere to generally accepted industry standards and maintain adequate protections in order to safeguard the information in our control; and we take steps to ensure that only those at Ginger Joy with a valid business need to access your personal information are entitled to do so. We also take reasonable precautions to ensure that third parties to whom we send information offer suitable safeguards for that sort of information. We care about the security of your personal information, but keep in mind that no method of Internet transmission or electronic storage is completely safe. While we make every effort to employ commercially reasonable procedures to protect your personal information, we cannot guarantee its complete security. If you have reason to believe that your personal information is no longer secure, please immediately contact us as set forth below in the “Contact Us” section.

• Transfers and Third Parties

Our Apps may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their respective Privacy Policies.

We may disclose your personal data:

• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
• With suppliers and subcontractors, as necessary for the purposes set out in this notice.
• With other members of our corporate group and our international network of partners.

If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

• International Transfer

Our operation is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.

• Storage

We retain your data for as long as your account is active or as needed to provide you with the Services.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

International Users

• USA Residents

California Residents: You have the right to know whether your personal data is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes.

• European Residents

European Residents: You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).

Your Rights

Users have the following rights, although these rights may be limited in some circumstances:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Contact Us

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: legal@gingerjoy.gs