Published: 02.07.2024

1. GENERAL PROVISIONS

1.1. This Privacy Policy ("Policy" or "Privacy Policy") has been developed by Pixel Technologies - FZCO ("Publisher"), a company registered and operating under the laws of the United Arab Emirates (registration number: DSO-FZCO-24339), referred to as the "Company". The goal of this Policy is to protect the personal data of Users who play multiplayer online games published by the Company (hereafter referred to as "User(-s)" and "Games," respectively). It establishes the procedures for processing and protecting information about individuals using the Company's services and products.
1.2. This policy is a mandatory document for all Users. By registering a Game account or using the Company's Games and services, Users acknowledge and agree to the terms for processing their personal data according to this Policy.
1.3. The company operates in accordance with this Privacy Policy and other regulatory legal acts applicable to the Company's processing of personal data.

2. WHO PROCESSES YOUR PERSONAL DATA

2.1. The company collects and processes Users' personal data to provide access to the Games and enable full functionality, including authorization on game servers and purchasing in-game items and currency. Personal data is processed by the company and third-party partners involved in delivering its services. Please note that third parties process personal data according to their privacy policies.
2.2. The Company may transfer the Users' personal data to the following categories of third parties:

• Payment Service Providers: for processing payments related to in-game purchases of items and currency, the Company may transfer necessary data to payment service providers, ensuring Users can securely and conveniently conduct transactions;
• Advertising Partners: for marketing and promotion of the Games, the Company may share specific data with advertising partners in accordance with this Privacy Policy;
• Operational Partners: to ensure the functioning and development of the Games, including hosting and technical support, the Company collaborates with various operational partners and transfers relevant Users' personal data;
• Government Authorities: if required by the applicable laws, the Company may disclose data to government authorities;
• Users of the Operator: in some Games, information about User profiles may be available to other players according to the privacy settings of the Game;
• Customer Support Partners: to provide quality support to Users, the Company may share data with partners who provide technical support services;
• Game Distribution Platforms: personal data is also transferred to platforms through which Users register accounts to access the Games, including app stores and other distribution services.

2.3. All listed categories of third parties process personal data in accordance with their privacy policies and the requirements of applicable law. The Company cooperates only with partners who guarantee sufficient information protection and confidentiality.

3. DATA COLLECTION AND PURPOSE

3.1. The Company collects only the personal data necessary to manage and provide the Games, fulfill its obligations, and support other related activities, including administration, operational functionality, and improvement of the Games. You may find the specific types and purposes of personal data processing below:
3.1.1. Access to Games and Functional Support:

• User Identification. Usernames and other necessary identifiers to ensure uninterrupted access to game features;
• Gaming Information. Characters, gameplay progress, levels, achievements, in-game statistics, guilds or team affiliations, and in-game transaction histories;
• Device Information. Device type, operating system, unique device identifiers, language settings, screen resolution, browser version, and other relevant technical details.

3.1.2. User Communications:

• Contact Information. Email addresses;
• Feedback. Inquiries, requests, suggestions submitted to support services, along with comments and feedback about the Games.

3.1.3. Game Quality and Research:

• Usage Metrics. User actions within the Game, including time spent, gameplay choices and preferences, and activity levels in various game sections;
• Technical Data. IP addresses, operating system details, device identifier information, and server logs.

3.1.4. Marketing Data Processing:

• Gaming Preferences. Genre preferences, participation in game-related events, promotions;
• Engagement Data. User responses to marketing initiatives, participation in surveys, research conducted by the Company.

3.2. If the Game allows User profile information to be visible to other players, the User agrees to make such information public, including details like game characters, achievements, and status. Users acknowledge that some of their information will be visible to other players based on the Game’s privacy settings.
3.3. The Company does not process biometric data or collect sensitive personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual life, or sexual orientation.
3.4. The Company utilizes cookies and similar tracking technologies to enhance User interaction with our websites and Game interfaces, as well as for analytical and marketing purposes. Cookies are small text files stored on a user’s device while visiting a website. They help the website remember User actions and preferences (such as login details, language, font size, and other display preferences) over time. This means Users don’t need to re-enter this information when they return to the site or navigate between pages. Users can adjust their browser settings to block or alert them about these cookies, although some areas of the site or Games may not function as intended if they do so. Acceptance of cookies is assumed if the user’s browser settings are configured to accept them when using the Company’s websites.

4. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

The Company processes users' personal data strictly according to the legal provisions of the applicable laws and international standards for personal data protection. This processing is based on the following legal bases:

• Contractual Obligations: personal data processing is carried out to fulfill a contract where the User is a party, beneficiary, or guarantor, including scenarios where data processing is necessary for entering into a contract at the User's request or where the User acts as a beneficiary or guarantor in relation to the Games;
• Legal Obligations: the Company processes personal data in compliance with the legal duties imposed by the applicable legislation;
• User Consent: personal data may be processed based on the user’s voluntary, informed, explicit, and conscious consent. Such consent is provided during the registration of a game account or throughout the use of the Games and associated services;
• Legitimate Interests of the Company: data processing may be conducted to fulfill the Company's rights and legitimate interests, as long as it does not compromise the rights and interests of Users as data subjects, particularly to prevent fraud, ensure the security of Users and the Games, and improve the quality of the Games and services provided.

5. DATA PROCESSING ACTIVITIES PERFORMED BY THE COMPANY

5.1. The Company engages in automated and non-automated (mixed) processing of data. In accordance with applicable laws, the Company performs the following operations: collection, recording, systematization, accumulation, storage, clarification (updating, modification, addition), retrieval, use, transmission (provision, access, distribution, cross-border transfer), blocking, deletion, destruction, anonymization, and protection of personal data.
5.2. To ensure access to the Games and their full functionality, the Company interacts with various distribution platforms and services that manage game accounts and other related services, including stores for purchasing in-game items and currency. By registering a game account through third-party services, the User agrees that their data will be transferred between the Company and these platforms to ensure the availability and functionality of the Game.

6. PRINCIPLES OF PERSONAL DATA COLLECTION, PROCESSING, AND PROTECTION

The Company follows these key principles in handling Users' personal data according to the applicable laws:

• Respect for Rights and Freedoms: we ensure that the constitutional rights and privacy of individuals are upheld during data processing;
• Lawfulness: we conduct all personal data activities legally in compliance with the specific requirements of applicable laws;
• Confidentiality: we treat personal data that require restricted access confidentially, ensuring access is limited to authorized personnel;
• Security Measures: we implement all necessary measures to protect personal data from unauthorized access, destruction, alteration, and other threats;
• Purpose-Specific Processing: we process personal data strictly for the purposes stated at the time of collection;
• Accuracy and Reliability: we maintain the accuracy, reliability, and adequacy of personal data relative to the purposes for which they are processed;
• Avoiding Excess Data: we collect only the personal data necessary for the stated purposes;
• Storage Limitation: we retain personal data in a form that allows User identification only as long as necessary for processing purposes;
• Consent for Processing: we process personal data for marketing and other purposes that require User consent only after obtaining such consent;
• Restriction on Public Access: we do not disclose User personal data in publicly accessible sources without explicit consent;
• Biometric Data Processing: we process biometric data only when there are legal grounds and a necessity for identity verification to protect User accounts;
• Automated Decisions: we do not make decisions that have legal consequences for the User based solely on automated data processing without their involvement.

7. PROCEDURE FOR THE COLLECTION, STORAGE, TRANSFER AND OTHER TYPES OF PERSONAL DATA PROCESSING

7.1. The Company implements all necessary measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, and other improper actions. Here are the actions the Company undertakes:

• Identifying Necessary Data: we determine the personal data necessary for activities related to providing access to multiplayer Games;
• Appointing Responsible Personnel: we designate employees responsible for organizing data processing and ensuring data security to coordinate protection efforts;
• Internal Control and Audit: we conduct regular internal controls and audits to ensure that personal data processing complies with the applicable laws and our internal policies;
• Employee Training: employees involved in data processing are trained in information protection rules and methods, as well as our privacy policies;
• Identifying Security Threats: we analyze and identify potential security threats to personal data during processing in our information systems;
• Implementing Protective Measures: we apply organizational and technical measures to ensure data security, including encryption, antivirus use, and protection from unauthorized access;
• Handling Recording Media: we take steps to track and secure media that contain personal data, preventing their loss or unauthorized use;
• Incident Detection and Response: we develop and implement procedures for timely detection and response to security incidents involving personal data;
• Data Recovery: we create conditions for recovering personal data if it is damaged or destroyed due to unauthorized access or other incidents;
• Access Restriction: we establish strict access rules to personal data processed in our information systems, with registration and accounting of all actions performed with the data;
• Monitoring Effectiveness: we continuously monitor the effectiveness and adequacy of the measures taken to ensure the security of personal data.

7.2. Besides the measures mentioned above, the Company takes steps to ensure compliance with data protection legislation during the cross-border transfer of personal data, including by entering into relevant agreements with partners and third parties.
7.3. The described measures are implemented considering the current state of technology, the implementation costs, the nature of the processed data, and the potential risks to data subjects' rights. The Company regularly reviews and updates these measures in line with advancements in data protection technologies, changes in legislation, and the evolving external environment.

8. DURATION AND LOCATION OF PERSONAL DATA PROCESSING

8.1. The Company retains users' personal data only for the period necessary to achieve the purposes for which it was collected. After this period, or if a User withdraws their consent to data processing, the data will be deleted or made anonymous within 30 days unless required otherwise by law.
8.2. Users can withdraw their consent to the processing of their personal data at any time. This includes collecting, using, and sharing their data, both within and outside the country. Users can do this by using the options provided on the Company's website or in the Game or by sending a written request to the following address: Dubai Silicon Oasis, IFZA Business Park, DDP, Building A1, Premises 26105-001, Dubai, United Arab Emirates Following the processing of the request, any personal data not required to be kept by law will be deleted promptly.
8.3. The processing and storage of users’ personal data take place within the United Arab Emirates in compliance with applicable laws. The Company utilizes specialized databases and information systems housed on secure servers in United Arab Emirates, ensuring high data security.

9. USER RIGHTS

9.1. In accordance with the applicable legislation and the terms of this Policy, Users have the following rights:
9.1.1. Right to Access. Users have the right to obtain confirmation from the Company whether their personal data is being processed and to access information about:

• the fact that personal data is being processed;
• the legal basis and purposes of processing;
• the methods of data processing;
• the name and location of the Company, and the identities of those who have access to the personal data;
• the periods for which the data will be processed and stored;
• any potential cross-border data transfers;
• the entities that process the data on behalf of the Company.

9.1.2. Right to Rectification. If a User believes that their personal data processed by the Company is incorrect or incomplete, they may request that the data be corrected or supplemented.
9.1.3. Right to Erasure and Restriction. Users may request the Company to block or delete their personal data if it was collected or processed unlawfully or if the data is incorrect or no longer necessary for the purposes for which it was collected.
9.1.4. Right to Object. Users may object to the processing of their personal data, including for marketing purposes. In case of disputes, Users have the right to seek protection of their rights through competent authorities.
9.2. Users may exercise their rights by submitting requests directly to the Company at Dubai Silicon Oasis, IFZA Business Park, DDP, Building A1, Premises 26105-001, Dubai, United Arab Emirates. The Company is committed to reviewing and responding to such requests in accordance with the applicable law.

10. FINAL PROVISIONS

10.1. The Privacy Policy is a publicly available document. The official version is posted on Pixel Technologies – FZCO’s website.
10.2. The Company reserves the right to amend this Privacy Policy. The new version becomes effective from the moment it is published on the Company's official website, unless otherwise provided by the terms of the updated Privacy Policy.
10.3. In the event of significant changes to the Privacy Policy that may affect users' rights and obligations, the Company will notify Users by posting relevant notices on its website. The Company may also use other methods of notification at its discretion.
10.4. A designated officer within the company is responsible for ensuring compliance with the requirements of this Privacy Policy, including reviewing its provisions. The officer coordinates processes related to the processing and protecting of personal data and ensures the Company's actions comply with the applicable laws and this Policy.