General Privacy Policy

Last updated: May25 2022

By using any of the Snapverse Games Applications/service, you are deemed to accept the terms of this Policy, and to expressly acknowledge and, where required, consent to our processing of the information you provide to us for the purposes outlined in, or otherwise in accordance with, this Policy.If you do not agree with the terms of this Policy,pleasedo not continue to use the Services;and in the case of applications, please uninstall the applications immediately.Your access and use of Snapverse Games Applications/serviceis also subject to ourTerms of Service, and all capitalized terms not defined in this Policy will have the meanings set forth therein.

Parental and Guardian Consent

Anyone under the age of 13 or the minimum age under the applicable laws of your jurisdiction (“Minimum Age”) shall not useSnapverse Games Applications/service.We will also not knowingly collect or store any personal information about children under the age of 13 without parental permission.

If you have reached the Minimum Age but are under the age of majority as defined under the applicable laws of your jurisdiction (“Majority Age”), you may only use and register aSnapverse Games Applications/serviceaccount (“Account”) through your parent or legal guardian’s representation, and your parent or legal guardian hereby represents you and accepts this Policy.

If you are a minor in your country or region, your use ofSnapverse Games Applications/servicemay be subject to further age restrictions, whether imposed by us or third-party vendors in connection with the provision of certain Services.You may be unable to use or only have limited access to those Services, such as, where applicable, some games with age restrictions,participating in rewards programs, top-up and tipping, without the assistance of your parent or legal guardian.

If you learn that a child under the Minimum Age has registered aSnapverse GamesAccount or an Account of a child under the Majority Age was not registered under proper supervision, representation or guardianship, you may alert us atchildprotection@kwaigamesglobal.com.We will promptly investigate, take steps to remove such child’s Account information from Snapverse Games Applications/serviceand terminate the child’s Account.

Summary of this Policy

This summary is not intended to substitute or replace any part of the Privacy Policy, but aiming to help Snapverse Games Applications/serviceusers understand the core information contained in the Privacy Policy through a quick overview. We strongly recommend that each user carefully read the entirePrivacy PolicyandTerms of Service.

Data we collect

We collect the data provided to us by Snapverse Games Applications/serviceusers. We may also collect data as you use our app services, and please refer to the privacy policy of our apps for specific Data we collected.

How data is used

We use the data we collect to deliver and maintain our services. Your data may also be used for troubleshooting, improving our services, or developing new ones. We may use the data we collect from you to optimize user experience. Where it is necessary, we may also use your data to ensure security of the platform, detect and prevent fraud, or comply with our legal or regulatory obligations.

Storage and transfer

We store your data in our data center located in Singapore. We use and keep your data to the extent that is necessary to achieve the purposes for which it is collected, including to provide our services to you, to fulfil our legal obligations, or to protect our legitimate interests.

Your data may be transferred internationally to our affiliates that adopt and comply with our global data protection standards. Any transfer to third parties will be in accordance with our Privacy Policy. Your data is protected and secured with appropriate technical and organizational measures.

Your rights in relation toyour data

You have certain rights in relation to your data, subject to applicable laws. Once you have completed your account registration and verification, you can review, modify, and delete your data. We may need to retain some of your data, like your initial registration information, for verification and security purposes.

You can also ask us to delete your account. This is an irreversible process as you will not be able to access your account upon deletion, and all data in relation to the account will be deleted, de-identified, or anonymized, subject to any statutory retention requirements under applicable laws and regulations.

Snapverse Games Pte. Ltd., whose registered address is at 1 Raffles Place #36-01 One Raffles Place Singapore 048616 (“we”, “us”, “our” or the “Company”) serves as the legal entity controlling and operatingSnapverse Games Applications/serviceand related websites. We value your privacy and data protection and arealways committed to protecting user data in our day-to-day practices. This Privacy Policy (this “Policy”) describes how we collect your personal data (“Data”) when you use any of our applications and/or services, and also explains how we use, store and share the Data we collect from you, as well as your rights in relation to the Data.

In this Policy, “you” or “your” refers to the authorized user of our Snapverse Games Applications/service.

1.Data We Collect

We may collect the following Data from and about you when you use Snapverse Games Applications/servicein accordance with this Policy and the privacy policy of our apps: such as contact information (such as email address)account registration or registration for using thegame services(such as user name, password,Data about your account, game progress and any use ofgame services), IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI), Cookies and similar technologies (see more below), Data we receive if you link a third-party application with the service (such as Facebook), Data for advertising and analytics purposes (with your consent), general location data (with your consent), and precise geo-location data (GPS, with your consent).

The categories and scope of Data we collect about you may vary from time to time, depending on your choice of and interaction with Snapverse Games Applications/service, as well as the country or region where you use Snapverse Games Applications/service. Where in-app purchase is available, data to complete transactions and/or payment will be further collected to enable such functions.

2.How We Use Your Data

We may use your Data for a number of purposes associated with operating our business and providingSnapverse Games Applications/serviceto you, in accordance tothisPolicyandthe privacy policy of our apps, including:

(1) To make sure theservices work properly and smoothly

To perform the contract, we process necessary data to

Ÿcreate accounts in order to allow you to play our games and use our Services;

Ÿoperate the Game and Services;

Ÿcommunicate with you about Service-related issues or information.

(2) To make the services more suitable for you

In order to provide a constantly optimized services to you, we have a legitimate interest to collect and process necessary data to

Ÿset up and update user profiles;

Ÿdevelop and improve the service as well as the user experience;

Ÿmanage our relationship;

Ÿcustomize your service experience;

Ÿrespond to your comments ,questions, and provide you with technical support;

Ÿwe provide customer service to you through our Game Services, other websites, and services, or by email;

Ÿsend you related information, such as updates, security alerts, and support messages.

(3) To show personalized advertisements (optional)

To show you personalized advertisements in the services as well as in other websites and services provided by us, we have a legitimate interest to process necessary data to

Ÿimprove advertising and other marketing and promotional activities; and/or

Ÿdeliver, target, and improve our advertising activities.

Please refer to the privacy policy of our apps for specific purposes of Data collection when you use our apps service.

3.Our Legal Basis for Processing Data

In order to process your Data, we will rely upon the legal bases afforded by applicable laws and regulations. In addition to your consent, which will always be limited to specific processing activities and include relevant, detailed information required for you to fully understand what you are consenting to, these legal bases may also include our compliance with legal obligations, the performance of an agreement with you, and our legitimate interests.

4.Data Storage and Retention

(1)We store your Data on our servers located in Singapore.We also have support, engineering, content moderation, and other functional teams located around the world to support Snapverse Games Applications/serviceprovided to you. We have rigorous internal control measures in place to strictly limit data access to designated personnel only.

(2)We will retain your Data for as long as necessary:(i) to achieve the purposes as set out in this Policy; (ii) as required by applicable laws and regulations, including any requirements to retain data for a certain period of time, taking into account the statute of limitations under applicable laws and regulations; (iii) for our legitimate and lawful purposes, including for our business, and provision of Snapverse Games Applications/service; and/or (iv) to defend against any actual, threatened or potential claims or disputes.

(3)We will not retain your Data for longer than necessary or beyond the end of the purposes for which you provided your Data to us, unless we are required to do so under applicable laws.In addition, we reserve the right to delete, destroy, or de-identify your Data that is no longer necessary or current for the purposes for which it was obtained, such as where the specific time period required under applicable laws have lapsed.

5.Data Security and Protection

(1)We will take appropriate technical and organizational measures to help protect and secure your Data. We will endeavor to protect your Data against unauthorized or unlawful processing, accidental loss, destruction, or damage through these measures, including:

(i)using encryption techniques;

(ii)establishing specialized systems and procedures, such as strictly limiting the scope of personnel with access to your Data, and requiring those who have such access to comply with relevant confidentiality obligations; and

(iii)forming a specialized department in charge of information security. In the event of incidents such as information leakage or data or security breach, we will take timely measures to handle such incidents, and we will notify you promptly in an appropriate manner, including through messages or announcements.

(2)We will endeavor to ensure that, by default, we only collect and process your Data needed to provide Snapverse Games Applications/service. We also apply this principle to our data privacy and protection controls in our processing activities. This means that we will neither publish nor share your Data by default.

(3)While we are committed to protecting your Data, no electronic data transmission or storage of information can be completely secure. If you do not agree to these risks and conditions, you must discontinue your use of Snapverse Games Applications/service.

6.To Whom We May Disclose or Transfer Your Data

(1) We will not share or transfer any of your Data to any third parties except as explicitly provided in this Policy. We will only share your Data with third parties in the following circumstances:

(i)when approved or authorized by you or subject to the “Parental and Guardian Consent” section, your parent or legal guardian;

(ii)as required for administrative or judicial purposes, including any requirements of competent authorities, courts and regulatory bodies;

(iii)in any legal proceedings (including arbitrations) against you in which we aim to protect our legal rights;

(iv)where expressly allowed by theTerms of Service;

(v)in order to protect the interests of the Company, you or the public against harm.

(2) We may share your Data with our corporate affiliates, group members, and the following third parties, who will only use your Data in accordance with this Policy to facilitate the provision of Snapverse Games Applications/serviceto you or for other purposes as indicated below.

(i)Social media platforms:To facilitate the provision of Snapverse Games Applications/serviceto you, we may share your Data with social media platforms of your choice: If you access Snapverse Games Applications/servicethrough third party social media platforms (such as Facebook, Google, Apple), we share certain information about you (such as account ID, access token and referring URL) with your selected platform. If you allow third party social media integrations with Snapverse Games Applications/serviceor share the content of Services on third party platforms (such as YouTube, Instagram, Facebook, Twitter, WhatsApp), depending on the content you choose to share, we may share certain information about you (such as account ID, user ID, photo ID and share URL) with your selected platform.

(ii)In the context of a transaction including mergers, acquisitions or asset sales: We may transfer your Data to another legal entity for the purposes of a collaboration, joint venture, corporate reorganization, change of legal form or other similar event. In order to develop our business, we may engage in transaction such as mergers, acquisitions, sales and asset transfers. In these circumstances, we will inform you of the related transactions, and will continue to protect or require the successor to protect your Data in accordance with applicable laws and regulations and this Policy.

(iii)Third parties in support ofSnapverse Games Applications/service: We may engage or cooperate with third parties to perform functions or provide services. We share your Data with these service providers for purposes such as hosting or operating our Services, payment and transaction processing, rewards, vouchers and commercial goods delivery (where applicable), cloud services, e-mail communication, research, survey, marketing and data analysis services. We may also share your Data with professional agencies and individuals that we engage to provide professional services to us, including advisors, auditors, lawyers and accountants. We will only share your Data on a need-to-know basis with third parties in order for them to perform corresponding functions and services, and we will request such parties to maintain appropriate security measures to protect such Data from unauthorized access or processing.

(iv)Legal, regulatory or government authorities: We may in limited cases transfer your Data to local (where you reside) or overseas authorities such as legal, regulatory, law enforcement, government and tax authorities, to satisfy our obligations or those of third parties (when they receive a request from an authority empowered by law to do so), pursuant to applicable laws and regulations.

(v)Promotions: If you choose to register for a promotion, such as a competition, sweepstakes, lucky draw, contest, reward program for users, your Data may be disclosed to third parties for the purposes of administering such promotion.

(vi)Advertisers and measurement service providers: Where advertising services are available to users, we share aggregate information, which no longer contains personal data, with advertisers and third-party measurement service providers to show the amounts and groups of users of our platforms who have viewed or clicked on an advertisement. We share your advertising ID and other device information such as your IP address with advertisers and measurement service providers so that we may recommend advertising content which may be of interest to you.

(vii)Other business partners: Where shopping features are available, our business partners may offer goods or services to you through Snapverse Games Applications/service. When you interact with or order such goods and/or services, we will share your Data such as your user ID with such business partners to facilitate your transactions and to show you the status of orders made through Snapverse Games.

(3)You may submit certain information through Snapverse Games Applications/service. Any such information that is meant to be shown to the public on our app will be disclosed publicly. This Policy does not apply to uses of any such information by third parties after it is uploaded and displayed on Snapverse Games Applications/service.

(4)Except as otherwise provided in this Policy, we will not disclose any of the Data collected from your use of Snapverse Games Applications/serviceto the public. If public disclosure is required by applicable laws and regulations, we will inform you of the purpose of the disclosure and the type of information disclosed.

7.International Data Transfer

We may transfer your Data to other countries or regions solely for the purposes set out in this Policy, in accordance with this Policy and applicable laws and regulations. Data disclosure as referred to in this Policy may involve a transfer of your Data to countries and regions that provide different levels of data protection. Applicable legal and regulatory requirements are taken into consideration before any cross-border transfer of your Data takes place and our policies are as follows:

(1)We may share your Data with our other group entities in other jurisdictions for internal, business and operational purposes in order to provide Snapverse Games Applications/service. We will ensure, by way of appropriate contractual guarantees which will also be in compliance with applicable laws and regulations, that all such entities with which we share your Data maintain appropriate security measures to protect your Data from unauthorized access or processing and will not share your Data with any third party unless you expressly agree otherwise.

(2)In order to provide Snapverse Games Applications/serviceto you, we may need to transfer your Data internationally to non-affiliated entities, which will only occur pursuant to the international transfer mechanisms available under applicable laws and regulations. If the country or region to which your Data is being transferred does not provide an adequate level of protection to your personal data as required by applicable laws and regulations, your Data may be transferred internationally based upon your prior consent, our exercise of a legal right, our compliance with a legal obligation, or the performance of a contract with you, among other mechanisms available under applicable laws and regulations.

8.Data Access and Management

(1)Once you have completed your Account registration and put in place reasonable and necessary authentication measures, you can review, modify, and delete the Data you have submitted to us by using the contact information provided in “Contact Information” of this Policy. In general, you can browse, modify, and delete your own information at any time, but you may not be able to modify certain initial registration information and verification information provided at the time of registration for security and identification purposes.

(2)You may have the following rights to the extent applicable under local laws and regulations which you can exercise by using the contact information provided in this Policy:

(i)You have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your Data is processed. You also have the right to obtain confirmation as to whether or not Data concerning you is being processed, and, where that is the case, to access such Data and obtain a copy thereof.

(ii)You have the right to request rectification of your Data. You also have the right to have incomplete Data completed.

(iii)Where you have provided your consent, you may withdraw your consent. If you withdraw your consent, we may continue processing your Data to the extent permitted by applicable laws.

(iv)You may also have other rights as described under the local laws.

(3)We will verify your identity first before we can fulfill your request. We will respond to your request within the timeframe as required by local laws.

(4)You can change your privacy settings on our app, such as making your account private, disabling the downloading of your posts, and disabling the reading of your clipboard, and managing the sync of your phone contacts or social network contacts/friends list.

(5)You may also be able to change your cookie settings as described in the section below to manage the data we collect using cookies.

(6)You can prevent us from obtaining your Data by suspending certain functions provided by our Services.

(7)You can ask us to delete your Account, which is an irreversible process as you will not be able to access your Account upon deletion, and all data in relation to the Account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations. If you wish to have your account deleted, you can contact us by using the contact information provided in “Contact Information” of this Policy or through the in-app setting related to “Account Deletion”.

9.Cookies

Cookies are pieces of information that any website or app may transfer to your browser that are then stored in your computer or mobile system. For example, the deposit of Cookies enhances your online experience by allowing us to save your preferences.

Required Cookies we may collect are as follows:

Categories

Cookies

snapversegames.com

did

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Hm_lpvt_xxxxxxxxxxxxx

Hm_lvt_xxxxxxxxxxxxxx

These cookies are necessary for our website to function and can be switched off in our systems. They are set totrack and count the system internal log in order to help distinguish whether the user is accessing from the web or in the app.Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. These cookies do not store any personally identifiable information. Please note that if you reject or block cookies from Snapverse Games Applications/service, Snapverse Games Applications/servicemay not function properly as intended.

10.Changes to the Policy

We may update, change or modify the terms hereof from time to time, and significant and substantial changes will be posted on this page or, where material and appropriate, notified to you by in-app message. We urge you to check regularly to see those changes to our policy.Unless otherwise regulated by applicable laws, any update, change or modification will become effective on the same day of notification, orannouncementand your continuous use of any of the Services after the update will be deemed as your acceptance for the updated Privacy Policy unless material changes are involved, in which case we may notify you in advance in accordance with applicable laws and obtain your consent again in the form of a pop-up window or any other forms required by applicablelaws when you log into our Services again.

11.Contact Information

If you have any complaints, suggestions or questions regarding this Policy or in relation to the collection, usage, storage, protection and other functions of your Data, please contact us via the in-app feedback or complaints functions or by email toprivacy@kwaigamesglobal.com. We will review the issues involved as soon as possible and reply to you in a timely manner as required by applicable laws. If you have any concerns regarding how we are handling your Data, please contact us. We will endeavor to address your concerns promptly.