SPIREJOY PRIVACY POLICY

Last Updated: November 22, 2024

1.INTRODUCTION

Welcome to the Product and Services operated by SPIREJOY LIMITED ("SPIREJOY"). This Privacy Policy (the "Privacy Policy" or "Policy") explains the privacy practices of SPIREJOY(The Google Developer Name of Us is "SPIREJOY GAMES", hereinafter referred to as "We"or "Our") regarding your personal information throughout our Services. We take seriously our responsibilities regarding information security in accordance with the provisions of the law on protecting personal information confidentiality and are committed to respecting the privacy rights and interests of all users of our services. We understand the importance of the personal data that you have entrusted to us and believe that we have a responsibility to manage, protect and process your personal data appropriately. This policy is designed to help you understand how we process the personal data that you have provided to us, whether now or in the future, as well as to help You make an informed decision before providing us with any of Your personal data. At the same time, this Privacy Policy is also considered a personal data processing notice sent to you before us proceeds to process your personal data. This Privacy Policy is also designed to assist Our customers currently residing in the European Union (EU) to understand their rights regarding personal data under the EU General Data Protection Regulation when they use the Services.

2.DEFINITIONS

1. "Service" or "Services" means SPIREJOY's games("Games") provided on the Googleplay or Appstore or the official website of SPIREJOY, and/or any products, services provided by SPIREJOY or its affliates or partners.
2. "Personal Data" means information in the form of symbols, letters, words, numbers, images, sounds or similar forms on the electromagnetic environment associated with you or helping to identify You. Personal Data is provided by you and you are responsible for the accuracy of the data.
3. "Personal Data Processing" is one or more activities affecting your Personal Data, such as: collecting, recording, analyzing, confirming, storing, editing, add, combine access, retrieve, withdraw, encrypt, decrypt, copy, share, transmit, provide, transfer, delete, destroy Personal Data or other related actions.

3.CONSENT

By checking the box agreeing to this Privacy Policy before using our Services, registering an account ("Account") or accessing the Website, You acknowledge and agree that you voluntarily, affirmatively consent to the processing of personal data and you accept all methods, requirements, and/or policies described in the Privacy Policy, and you hereby consent us to process your personal data as described in this Privacy Policy ("Consent").

IF YOU DO NOT AGREE US TO PROCESS YOUR PERSONAL DATA AS DESCRIBED IN THIS POLICY, PLEASE DO NOT REGISTER AN ACCOUNT, USE OUR SERVICES, OR ACCESS THE GAME OR ACCESS THE SPIREJOY OFFICIAL WEBSITE. If we change our Privacy Policy, We will post those changes or the revised Privacy Policy on the official website, within the Game, and/or other Services of us. We reserve the right to amend this Privacy Policy at any time without prior notice to You.

4.WHEN WILL WE COLLECT PERSONAL DATA?

We will/may collect Personal Data from you:

1. When you register and/or use our Services, Games or Website/applications of the SPIREJOY, or register an Account with Us;

2. When you submit any forms, including, but not limited to, application forms or other forms in relation to any of our products and services, whether online or otherwise;
3. When you enter into any agreement or provide other documents or information in connection with your interaction with Us, or when you use our products and services;
4. When you interact with us, such as through telephone calls (which may be recorded), letters, faxes, face-to-face meetings, social media platforms and email;
5. When you use our services, or interact with us through the Games or the Website or Services provided by SPIREJOY or its affiliates or partners. This includes, but is not limited to, through Cookies that we may deploy when you interact with our games website or Services;
6. When you make transactions through our Games or Services;
7. When you provide feedback or submit complaints to us;
8. When you register to participate in a contest, game, event and/or promotion program related to the Games, Services provided by SPIREJOY or its affiliates or partners;
9. During your playing in the Game(s), use of the Site and Our Services; and
10. When you submit your personal data to us for any reason.

The above are only some common cases in which we collect your Personal Data, and do not reflect all the cases in which we will collect your personal data. You may contact us at official@spirejoy.com if you have any concerns on our collection of your Personal Data.

5.WHAT PERSONAL DATA DO WE COLLECT?

The personal data that we may collect includes, but is not limited to, the following basic personal data:

1. email address;
2. Your gender and your age;
3. Other personal data may contain in your Google Account or Facebook Account or other third party account if you choose the relevant login method.

For the avoidance of doubt, in any case, We will not process any of your Personal Data that is sensitive personal data under the current provisions of the law on personal data protection.

You agree not to provide us with any data that is sensitive personal data, inaccurate or misleading and you agree to notify us of any inaccurate data or changes to such data. We reserve the right at our sole discretion to request you to provide other documentation necessary to verify the information you provide to us.

If you use your social media account (such as Facebook, Google), application account (such as Apple account) (''Social Media Account') and/or your phone number to log in, use our Services or link to an account that you have registered with us, you understand and agree that, We may access your personal data when and only when you and the social media account service provider agree and authorize us to do so.

You have the right to edit, request correction, request provision or deletion of Personal Data you have provided to us, or you can also withdraw your consent at any time if you do not want us to continue to collect the Personal Data as described above.

However, you should note that, your refusal, withdrawal of Consent allows us to process your personal data or request deletion of whether the personal information you provide to us may affect your use of our services. You can find more information about this in Section 14 below.

6.PERMISSION

The data your device sends to us may include: data about you, recorded by our servers when you use our Services. This information typically need the following permission, but is not limited to:

1. Your IP address; your mobile device operating system;
2. Your mobile device type, mobile device identifier, your mobile device's unique device identifier (UDID) or mobile device identifier (MEID);
3. Your Geo Location (if you give consent to us when we ask you in Games);
4. Your Camera(if you give consent to us when we ask you in Games);
5. Access to External Storage(for in-game data storage)

If you log in, the information collected based on permission above will be linked to your personal Account. These information (not including your Personal Data) is also included in statistics to help us measure how our customers use our Games and Website.

7.COOKIES

We may from time to time use "Cookies" or other features to allow us or third parties to collect or share information that will help us improve Our Site, Games and the Services We provide, or help us offer new services and features.

"Cookies" are identifiers we send to your computer or mobile device that allow us to recognize your computer or device and tell us when the Services or Sites are used or visited, by how many people, and to track activity on our Site or Games.

Cookies are also linked to information about the content you have selected for shopping pages you have viewed, or games you have played.

Cookies are also used to deliver content based on your interests and to track usage of the Services.

You may refuse the use of Cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of our Website, Games or Services.

8.HOW DO WE USE THE PERSONAL DATA YOU PROVIDE TO US?

We may process your personal data for one or more of the following purposes:

1. To respond to legal proceedings, comply with applicable laws and at the request of competent state agencies;
2. To consider and/or process your application/transaction with us or your transactions or correspondence with third parties via the Services;
3. To manage, operate, provide and/or administer your use of and/or access to our Services, websites and games and partner services , these including but not limited to: your preferences, your Account, your relationship with us;
4. To respond to, process, resolve, complete a transaction and/or fulfill your requests for certain Services, products;
5. To notify you of problems with the Services, as well as unusual Account activity;
6. To enforce our TERMS OF USE or any other applicable end-user agreements, terms;
7. To protect the personal safety and rights, property or safety of others, or persons in your care;
8. To identify and/or verify your Account;
9. To maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth operation of our Services;
10. To deal with or facilitate the customer service department to carry out your reasonable requests, respond to any queries sent by you or sent by someone else on your behalf, provided that the person on your behalf has sufficient documents to prove that you have authorized them to carry out such tasks, requests;
11. To contact you by telephone, text message, fax message, email, mail or other means for the purposes of administering/managing each relationship between you and us or your use of our Services, including but not limited to communicating information to you in relation to our Services. You acknowledge and agree that We may contact you by sending you a letter by post or sending you a notice through appropriate means of communication, which may disclose certain Personal Data about You (e.g., disclosure of Personal Data written on a postal envelope);
12. To notify you when another user has sent you a private message or posted a comment to You in the Games, on the Site or Our Services;
13. To conduct research, analysis and development activities (including, without limitation, data analysis, surveys, development and/or profiling of products and Services), to analyze how you use

Our Services, with the aim of improving Our Services or products and/or improving your customer experience;

14. To enable advertising and other audits and surveys, validate the size and composition of our target audience, and understand their experiences with our Services;
15. For marketing purposes. In this case, through various means of communication, we will send you information, marketing and promotional materials relating to our products and/or services, whether they are existing or created in the future;
16. To compile statistics and research for our internal reporting and/or record keeping requirements or as required by applicable laws, regulations, and rules;
17. To conduct due diligence, verification or other floor activities (including but not limited to background checks) to comply with our legal or regulatory obligations, or our established policies and procedures, where these policies and procedures are required by law or have been adopted by us;
18. To audit our Services or our operations;
19. To prevent or investigate any actual or suspected breach of our TERMS OF USE, including but not limited to fraud, misconduct, omission or any other misconduct whether or not related to your use of our Services or any other matter arising out of your relationship with us;
20. To store, host, back up (including for disaster recovery purposes including but not limited to war, peace, natural disasters and/or other serious incidents..., or otherwise) your Personal Data; and/or
21. Any other purposes that We notify you of at the time of obtaining your Consent.

(collectively, the “Purpose” or “Purposes”).

Because the purposes for which We will/may collect, use, disclose or process your Personal Data depend on the circumstances, such purpose may not appear above. However, We will notify you of such other purpose at the time of obtaining your consent, unless processing of personal data without your consent is permitted under the provisions of the personal data protection laws or other applicable laws.

By giving your consent, you agree to us processing your personal data for all of the above purposes. If you only agree to one or some of the purposes, please do not tick the box agreeing to this Privacy Policy. However, You should note that this may affect your use of our services.

9.HOW DO WE PROTECT AND STORE YOUR PERSONAL DATA?

We implement various security measures and strive to ensure the security of your personal data on our systems. Your personal data is stored behind secured networks and is only accessible by a limited number of employees who have special access rights to our systems. However, there are no guarantee of absolute security.

The period for which we process your personal data is calculated from the time we obtain your consent until the last time your use our services and continues for a minimum of five years from that point. Even if you request that we erase your Personal Data in accordance with Section 14.2, we may still be required to continue to store, use and/or disclose your Personal Data in accordance with this Privacy Policy to comply with our obligations under the personal data protection laws and other relevant laws.

We will retain personal data in accordance with the personal data protection laws and/or other relevant laws. This means that we have the right to erase your personal data where we have reasonable grounds to determine that (i) the purpose for which we process that personal data is no longer being served by storing that personal data; (ii) retention is no longer necessary for any legal or business purposes and (iii) there is no other legitimate interest in continuing to retain such personal data. Subject to applicable law, We may securely delete your personal data without prior notice.

10.DO WE DISCLOSE YOUR PERSONAL DATA?

In the course of conducting our business, we will/may need to your personal data to Game developers, service providers, third parties, agents and/or other third parties, for one or more of the above purposes. Such third-party service providers, agents and/or other third parties will process your personal data on our behalf or for one or more of the above purposes.Such third parties include, but are not limited to:

1. Contractors, agents, service providers and other third parties that we engage to support our business. These include, but are not limited to, those who provide administrative or other services to us such as postal companies, telecommunications companies, information technology companies and data centres;
2. A purchaser or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether pending or in the course of bankruptcy, liquidation or similar proceedings, in which personal data we hold about our users is included in the assets transferred;
3. Or to a counterparty to a business asset transaction in which we are involved; government authorities;
4. And third parties to whom we disclose information for one of the purposes and those third parties will collect and Process your Personal Data for one or more purposes in turn.

You agree that, when using the services/products/games of our partners integrated on the SPIREJOY Services, You agree to allow us to share your personal information, your data when using the services/products of our partners. In this case, third parties may request us to disclose your game playing history and/or disclose records showing which IP addresses have viewed which games. We will also share statistical information about your use of the Services with these third parties. This will not include any information that could be used to identify you specifically or disclose personal data about you. For clarity, We may disclose your personal data without your consent where the provisions of the personal data protection law or other applicable laws permit us to do so. Third parties may intercept or access personal data sent to or available on the website, the software, applications, technologies used may result in incorrect or unintended operation, they may access, abuse or misuse information through no fault of ours. However, we will implement reasonable security measures to protect your personal data in accordance with the provisions of the personal data protection law; However, we cannot guarantee absolute security because a third party may have unauthorized access to personal data sent to or contained in the game, on the website or the software, applications, technologies used, which may result in incorrect/unintended operation, or someone accessing, abusing or misusing personal data through no fault of ours.

11.PERSONAL DATA OF CHILDREN (EXCEPT CHILDREN WHO ARE BORN IN THE EU)

Our Services are available to a wide range of people of different ages. For children under age of 18, creating an account and using our services requires the consent and supervision of the child's parent or guardian.

Parents or guardians of children under age of 18 should supervise and ensure that the child under age of 18 they are protecting does not register for an account to use the services and/or provide their personal data to us without the consent and supervision of the child's parent or guardian.

In the event that personal data of a child under age of 18 is provided to us by a parent or guardian, the parent or guardian hereby consents to the processing and use of the personal data of the child under age of 18 in question, and agrees to be governed by this Privacy Policy on behalf of the person being protected. At the same time, the parent or guardian undertakes and warrants that the personal data of the child under age of 8 or older under his/her care has the child's consent, in addition to the consent of the parent or guardian, before such data is provided to us.

The parent or guardian of a child under age of 18 agrees that, in addition to the Personal Data of the child under age of 18 provided to Us by the parent or guardian, We may request the provision of personal data of the parent or guardian of the child under age of 18 for the purposes in point of Section 6 of this Privacy Policy. We will close any account used by a child who does not comply with the requirements set out above and will remove/delete any personal data that we believe has been submitted to a child user under 18 years old and not meet the above requirements.

12.PERSONAL DATA COLLECTED BY THIRD PARTIES

Our Services may use analytics tools (such as Google Analytics, Facebook Pixel, etc.) ("Analytics Tools"). These Analytics Tools may use cookies, which are text files placed on your device, to help the website analyze how users use our services. The information generated by the Cookies about your use of the website (including your IP address) will be sent to and stored by the Analytics Tools service provider. The Analytics Tools service provider will use this information to evaluate your use of our Services , compile reports on website activity for website operators, and provide other services related to website activity and Internet usage.

Our Services may use measurement tools (such as AppsFlyer,Adjust, Firebase, etc.) ("Mobile Measurement Partners", "MMPs"). The MMPs use a Software Development Kit ("SDK") placed on your device to help us monitor and optimize the delivery of the Services to you. Information generated by the SDK about your use of our application (including your IP address) will be sent to and stored by the MMP provider. The MMP provider will use this information to evaluate your use of our Services, compile reports on application activity for developers, operate the application, and provide other services related to application activity and Internet usage.

We, and third parties, may provide software application downloads for you to use on or through the Services. These applications may access your own, and allow a third party to view, your identifiable information, such as your name, your user ID, your device's IP address, or other information such as the Game you are playing during any particular session, and any cookies, SDKs you may have previously installed or that were installed for you by a third-party software application or website. In addition, these applications may ask you to provide additional information directly to third parties. The third-party products or services provided through these applications are not owned or controlled by SPIREJOY. You should read the terms and other policies published by such third parties on their websites or elsewhere.

The SDK that we intergrated in our Services is shown below:

13.EXCLUSION OF LIABILITY FOR SECURITY OBLIGATIONS FOR THIRD PARTY SITES

WE DO NOT GUARANTEE THE SECURITY OF YOUR PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES, APPLICATIONS.

We implement various security measures to maintain the security of Your Personal Data that We store or control. Your Personal Data is contained behind secured networks and is only accessible to a limited number of persons who have special access rights to our systems, and who are required to keep the personal data confidential. When you begin to use the Services or access your personal data, We recommend the use of a security device. All personal data provided will be encrypted into our databases so that it can only be accessed as described above.

In order to provide You with increased value, We may choose various third-party websites to link to, and frame within, the Website or Games. We may also enter into co-marketing and other relationships to offer e-commerce services, advertising, and other services and features to our visitors. These linked sites have their own and independent privacy policies and security measures. Even if such third parties are affiliated with us, we do not control these linked sites, each of which has its own privacy and data collection practices, independent of us.

Data collected by our co-marketing partners or third-party sites (even if provided on or through Our Site or Games) may not be received by us.

We therefore have no responsibility or liability for the content, privacy measures (or lack thereof), and activities of third-party websites, applications. We protect the integrity of our website and Our Games and the links placed on each of them, and therefore we welcome feedback about these linked sites (including, but not limited to, if a particular site does not work) using the contact information that can be found in Section 15 of this Policy.

14.HOW CAN YOU WITHDRAW YOUR CONSENT, CORRECT OR REQUEST TO CORRECT, PROVIDE OR DELETE PERSONAL DATA YOU HAVE PROVIDED TO US?

14.1. Withdrawal of Consent

You may withdraw your consent to the collection, use and/or disclosure of your personal data that we hold or control by following the instructions on our account settings page. We will process your request in accordance with the provisions of this Privacy Policy, the instructions, procedures on our account settings page and our obligations as prescribed by law.

You understand that Your withdrawal of consent will not affect the lawfulness of our processing of the data You have consented to before your withdrawal.

However, You should note that your withdrawal of consent means that we will not be able to continue to provide the services to you, and we may need to terminate your existing relationship with you and/or your contract with us without compensation for any losses you may suffer.

14.2. Editing, Requesting Correction, Providing or Deleting, Destroying Personal Data

Once you have registered an Account with Us, You can access to view edit Your Personal Data that We have collected, are storing or control under the Consent, through Our available systems. If You have not registered an Account with Us, or for certain Personal Data of Yours for which We have a separate process for correction, You may request correction of Your Personal Data that We hold in store or control in the manner specified at our services . We will process the request in accordance with the provisions of this Privacy Policy, the Customer Support process and Our obligations as prescribed by law. You can monitor Your Personal Data that We hold in store or control by checking the Personal Data displayed on Your Account Settings Page or request Us to provide it in other ways under Our Customer Support process. Your legal guardian or a person authorized by you may also make a request on your behalf. We will process the request in accordance with the provisions of this Privacy Policy, our Customer Support procedures and our obligations under the law.

You may request that We delete your Personal Data that We hold or control where You (1) consider that your Personal Data is no longer necessary for the Purposes for which You have given Consent, (ii) withdraw your Consent in accordance with Section 14.1, (iii) object to Us processing your Personal Data and We have no legitimate reason to continue processing your Personal Data, (iv) our processing of your Personal Data is inconsistent with the Purposes for which You have given Consent, and/or for other reasons as provided for by the Personal Data Protection law. You may request the deletion of your Personal Data that we hold or control in the manner instructed by our account settings page. However, you should note that if you request the deletion of your Personal Data, it will mean that we will not be able to continue to provide the services to you, and we may have to terminate your existing relationship with you and/or your contract with us without reimbursing you for any losses.

You should note that, in all cases, we will have enough information from you to determine your identity and the nature of your request to be able to deal with your request in accordance with our procedures. We may charge you a reasonable fee for dealing with and processing your request. If we do charge a fee, we will provide you with the fee and the timeframe for payment in writing or by email. Please pay and pay the above fees (if any) on time so that your request can be processed promptly. We have the right to refuse to provide or delete your Personal Data in specific cases as prescribed by law.

15.ADDITIONAL PROVISIONS FOR USERS IN THE EUROPEAN UNION (EU)

The provisions of this Section apply only if You are located in the European Union (the "EU"). They prevail over any other provisions of this Privacy Policy.

15.1. Portability

(a) You have the right to receive from Us the Personal Data that you have previously provided to Us and which has been processed based on your Consent in a structured, commonly used and electronically accessible format, and to request Us to transfer this Personal Data to another Party. If you wish Us to transfer Personal Data to a Third Party, Please provide the details of the Third Party and note that We will only be able to comply with your request if it is technically feasible. We will not be responsible for the security of Personal Data or Data obtained as a result of processing Your Personal Data by the Third Party that receives it. We may also not provide you with certain Personal Data about you if providing it would interfere with other rights (for example, if providing Personal Data that We have collected would reveal information about another individual).

15.2. Deletion of Data

You may request Us to delete Personal Data about You that We have collected in the following circumstances:

(1)You believe that the Personal Data is no longer necessary for Us to hold your Personal Data;

(2)We process Your Personal Data that We have collected based on your consent and You wish to withdraw this consent. At the same time, We no longer have any other reason or purpose to continue processing this Personal Data;

(3)We are processing Your Personal Data based on Our legitimate interests and You are the subject of this processing. Please provide us with the details that You consider reasonable so that We can consider whether it is an overriding interest of Us to process and store this Personal Data;

(4)You no longer wish Us to continue using Your Personal Data that has been collected by Us to send advertisements, special offers, sales programs and lucky programs;

(5)or You believe that the Personal Data we collect about you is being processed unlawfully by us.

Please provide as much detail as possible about your reasons to assist us in determining whether you have a legitimate basis for requesting erasure. However, we may retain Personal Data if there is a legal reason for us to do so (for example, to comply with the laws of the country where a SPIREJOY affiliate is headquartered, or to defend us against legal claims or to protect freedom of expression), but we will inform you of these circumstances. Please note that after deleting your Personal Data, we may not be able to provide you with the services you provided before deletion because we will not be able to know your preferences.

You should note that, in some countries (such as Brazil), territories, regulations require Service Providers such as SPIREJOY to store information, Personal Data of users for a certain period (possibly up to five years) ('Storage Period') from the last time that the user uses the service; You agree that, in this case, the regulations of the above countries and territories will take precedence; therefore, your request to delete Personal Data will only be possible after the end of the above Storage Period.

15.3. Retention of Personal Data

We retain your Personal Data for as long as it is necessary for us to provide services or products to you, or as required or permitted by law, such as the laws on online gaming, Tax, Accounting. If you make a request to delete your Personal Data and we determine that this is a valid request, We will attempt to delete your Personal Data within 30 days of your request and the end of the above Retention Period, or notify you if it will take longer.

15.4. Objections to Profiling and Targeting

At any time, you have the right to object to the processing of your Personal Data for the purpose of sending you promotional programs, special offers and sales messages, including our building of customer profiles for these purposes, and we will stop processing your Personal Data for these purposes. Please provide us with detailed information about your reasons for your request to assist us in determining whether you have legitimate grounds to object. However, we retain Your Personal Data if there are legitimate grounds for Us to do so.

15.5. Restriction of Processing of Personal Data for Storage Purposes

You have the right to request that We restrict the processing of your Personal Data that We have for storage purposes only, where:

(1)You believe that Your Personal Data is inaccurate, for the period necessary for Us to verify whether Your Personal Data is accurate;

(2)We want to erase Your Personal Data but You want Us to Retain;

(3)We want to erase Your Personal Data because it is no longer necessary for Our purposes but You require storage to establish, exercise, or against legal claims; or

(4)You object to Us processing Your Personal Data on the basis of Our legitimate interests and You want Us to stop processing Personal Data when We determine whether it is important to process and retain the Personal Data.

15.6. Transfer of Personal Data Outside the EU

Your Personal Data may be transferred outside the EU. We will take necessary and appropriate steps to ensure that the recipients of Your Personal Data are responsible for keeping them confidential and We take measures such as appropriate contractual provisions to ensure that the recipients of the transferred data protect and process Your Personal Data in compliance with all applicable data protection laws.

15.7. Children's Information

These Services are not directed to children under the age of 18 who are currently residing in the EU We do not knowingly collect or store any personal data or non-personally identifiable information from anyone under the age of 18 who is currently residing in the EU, nor is any part of our Site, Games or other Services directed to children under the age of 18 who are currently residing in the EU. We will close any Account that is used exclusively by such a child and will remove and/or delete any personal data that we believe was submitted by any child under the age of 18 who is currently residing in the EU.

16.PERSONAL DATA STORAGE AND TRANSFER TO OTHER COUNTRIES

For Services provided to the Brazil market, they will be stored in Brazil in accordance with the provisions of Brazil law.

For Personal Data of EU users, the provisions of Section15 of this Policy will apply.

17.Disclaimer of Warranty

This game is meant for adult players of age 18 or older and does not provide real money gambling or opportunities to win cash or prizes. The game's virtual assets have no value in the real world. Playing or excelling in this game does not indicate future success in real money gambling.

18.QUESTIONS, FEEDBACK AND CONTACT US

If you have any questions, feedback or questions about this Policy, contact Us at official@spirejoy.com