for Huuuge services’ s

15. Amendments to the

THE DEFINITIONS WE USE

1.1. Where we use a capitalised term in this Privacy Policy, it shall have the meaning set out below:

1.1.1.Controller – the natural or legal person, public authority, agency or other body which, alone or tly with others, determines the purposes and means of the processing of Personal data.

1.1.2. t – Controllers – two or more Controllers tly determine the purposes and means of processing the same Personal data.

1.1.3. Personal data (also known as personal information or personally identifiable information / PII) – all information about You that makes it possible to identify You directly (e.g. Your e-mail address) and indirectly (e.g. Your activity on the respective website). You can find more information about which of Your Personal data we process in Section 3 below.

1.1.4. Games – any game that the Huuuge provides to You through Mobile App or other platforms or Websites.

1.1.5. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC. The GDPR imposes specific obligations on entities that perform operations on Personal data (whether on their own behalf or on behalf of another entity). It guarantees the exercise of Your data protection rights – You will read more about this in Section 6.

1.1.6. We, Huuuge – companies in the Huuuge Group (group of undertakings) providing Service or access to the Games, indicated in section 2.1. below, acting together as the t-Controllers.

1.1.7. Mobile App – any mobile application through which Huuuge grants access to some Games and/ or provides any Service.

1.1.8. Website – any Huuuge website through which Huuuge may grant access to Games and/or provide any Service.

1.1.9. Service – any other service Huuuge provides to You through any Mobile App or any Website or any third party platform.

1.1.10. You, Your – the individual accessing or using the Games, any Website, any Mobile App or any Service.

1.1.11. Game Currency – in-game virtual currency.

1.1.12. Virtual Goods – in-game virtual items such as game virtual currency, level boosts, skins, etc.

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

2.1. The t – Controllers of Your Personal data in each case are (regardless of which of our Games or Services You use):

2.1.1. Huuuge Global Limited, with its ed seat in Limassol, Cyprus; address: 28th October Street, No. 331, Kanika Enaerios, Lido House, Block 1, Office 762, 3106 Limassol, Cyprus, e-mail address @huuugegames.casinowinning.net and

2.1.2. Huuuge Games sp. z o.o., with its ed seat in Szczecin, Poland; address: Storrady Świętosławy 1A/501, 71-602 Szczecin, Poland, e-mail adress @huuugegames.casinowinning.net.

2.2. We, the t-Controllers, may use our s from Huuuge Group: Huuuge Publishing Limited (formerly known as Fun Monkey Ltd.) or Billionaire Games Limited as service providers to provide the Services to You.

2.3. Facebook Ireland Limited and Huuuge companies indicated in section 2.1. above are t – Controllers when it comes to using a Facebook tool which enables You to connect Your Facebook s to the Website or Mobile App (Facebook ). The t – Controller addendum can be found here.

2.4. Similarly, when using TikTok marketing services (with respect to the data collected via TikTok business products) TikTok Information Technologies UK Limited and TikTok Technology Limited (collectively) and Huuuge companies indicated in section 2.1. above act as t – Controllers – more in the Tik Tok t Controller .

FOR WHAT PURPOSE, ON WHAT LEGAL BASIS AND WHICH OF YOUR PERSONAL DATA WE PROCESS?

PROVISION OF SERVICES AND GAMES ACCESS

3.1. When You use Our Mobile Apps, visit Our Websites, play Our Games or use other Services We provide, We only process the Personal data necessary to provide the service to You. Additionally, in some other cases, You may voluntarily provide us with more information or allow us to collect them, but we will not require it.

3.2. You may voluntarily e.g. create a player profile in our Games which other players can see and which may include the other, addition Personal data that You provide. It is not obligatory to create a player profile and to provide any additional Personal data. If You do not wish to, You do not have to do so in order to play our Games.

3.3. If You access our Games or Services from a third-party application or connect our Games or Services to a third-party application, You should also read that third-party application’s of use and their .

PROCESSING PURPOSES	LEGAL BASIS FOR PROCESSING	TYPES OF DATA
Creation and maintenance of an in-game	Necessity for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract (Article 6 (1)(b) of GDPR); with regard to additional data provided, the legal basis for processing is Your consent (Article 6(1)(a) of GDPR)	Required data: nickname player ID country Additional data: profile photo first and last name gender age city e-mail address data indicated in the description physical location data that You provide
Provision of electronic services (in of providing access to the content of the Games and Services)	Necessity for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract (Article 6(1)(b) of GDPR)	data about the ways in which You use and interact with our Games or Services such as when and for how long You play, game features and other players You interact with, etc. crash data such as crash logs if You choose to use communication features that allow You to communicate or share information with other players, then We would collect information on what is communicated or shared
Logging in with a Facebook or with an Apple ID	Your consent (Article 6(1)(a) of GDPR)	In case of Facebook : Facebook Friends’ List Facebook profile photo data used to In case of Apple ID : data used to
Analysis of Your activity in our Games or Services in order to: a) optimize the Games and Services/ adjust the gameplay and offers to Your needs, b) conduct some marketing activities c) detect fraud.	Legitimate interest of Huuuge (Article 6(1) (f) of GDPR which is some form of analysis of Huuuge’s players behaviours in order to learn and optimize the services and provide the services that are free (free to play games).	IP address or other location data (e.g. GPS-level data), time zone type of computer or mobile device You are using, device push tokens, platform type (like Apple iOS or Android) operating system version, network information mobile device’s identifiers, like Your MAC Address, Apple Identifier For Advertising (IDFA), Android Advertising ID (AAID), App Set ID and/or Google Advertising ID (GAID) browser type and language clicks on an app feature or web page time spent on an app feature or web page Game state and the date and time of activity on Our Game data about the ways in which You use and interact with our Games or Services such as when and for how long You play, game features and other players You interact with, etc. crash data such as crash logs product preferences, privacy preferences or other s choices

VIRTUAL GOODS PURCHASES

PROCESSING PURPOSES

LEGAL BASIS FOR PROCESSING

TYPES OF PERSONAL DATA

Fulfilling a submitted purchase order and providing the Virtual Goods

Necessity for the performance of a contract (Article 6(1)(b) of GDPR)

ID,
information on transaction

In cases where not via intermediary such as Google, Apple, also additionally:

last and first name
e-mail address
billing address
device ID
IP address / location
order ID
tax ID / status

Performing the statutory obligations imposed on Huuuge, in particular those following from tax and ing laws

Legal duty (Article 6(1)(c) of GDPR)

ID,
information on transaction

In cases where not via intermediary such as Google, Apple, also additionally:

last and first name
e-mail address
billing address
device ID
IP address / location
order ID
tax ID / status

COMMUNICATION, OUR RELATIONS WITH YOU AND MARKETING

3.4. We may send You direct marketing communications via email, from Mobile App or via push notifications.

3.5. We may also You from time to time to conduct a satisfaction survey to determine Your satisfaction with the quality of Our Games and Services.

PROCESSING PURPOSES

LEGAL BASIS FOR PROCESSING

TYPES OF PERSONAL DATA

Direct marketing communication or satisfaction surveys, maintaining relationship with You

s consent (Article 6 (1) (a) of GDPR)

Legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR) consisting of conducting marketing activities and satisfaction surveys

email address or telephone number
information about device (e.g. for push notifications)

REWARDS PROGRAM

3.6. If You participate in the Rewards Program, at times, We might need some more Personal data to actually provide You with a benefit, e.g. to send You a gift in real life, organize events for our best players, and communicate with You easier.

3.7. It may also happen that in the course of our closer communication You share with us some information that are treated as special categories of Personal data such as racial or ethnic origin, political opinions, religious or philosophical beliefs or information concerning health – please however note, that We do not collect such data by ourselves and We will never ask for it.

PROCESSING PURPOSES

LEGAL BASIS FOR PROCESSING

TYPES OF PERSONAL DATA

Providing benefits connecting to participation in the Rewards Program

With regard to obligatory personal data legal basis for processing is a necessity for the performance of a contract (Article 6(1)(b) of GDPR).

With regard to additional personal data legal basis for processing is a legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR), consisting of providing rewards and communication relating to the Rewards Program.

Obligatory personal data:

player ID
e-mail address

Additional personal data:

first name
last name
home address
phone number
Your social media details
additionally, We may also collect the content of Our chats together

SOCIAL MEDIA PROFILES

3.8. If You visit our profiles on social media (Facebook, Instagram, Twitter, Medium, LinkedIn, YouTube), We use Your Personal data exclusively in connection with the running of the respective profile.

PROCESSING PURPOSES	LEGAL BASIS FOR PROCESSING	TYPES OF PERSONAL DATA
Running of the respective profile, including to keep You informed about our activities, our Games and Services and to promote various events, services and products	Legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR), consisting of promoting one’s own brand	personal data that You make public on the relevant social media platform

OTHER PURPOSES OF PROCESSING

PROCESSING PURPOSES	LEGAL BASIS FOR PROCESSING	TYPES OF PERSONAL DATA
Handling complaints	Necessity for the performance of a contract (Article 6(1)(b) of GDPR)	the information You give Us (generally, Your name, e-mail address, player ID) subject of the complaint content of the complaint
Handling of data subject requests	Legal duty (Article 6(1)(c) of GDPR)	the information You give Us (generally, Your name, e-mail address, player ID) subject of the request content of the request
Handling of other requests and applications	Legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR), consisting of responding to enquiries addressed to it regarding its business activities; with regard to the data provided on an optional basis, the legal basis for processing is consent (Article 6(1)(a) of GDPR)	the information You give Us (generally, Your name, e-mail address, player ID) subject of the request content of the request
Improving electronic services quality	The legitimate interest of the Huuuge (Art. 6(1)(f) of GDPR) consisting of conducting analyses of Your activities on the Mobile App and Websites in order to improve the functionalities used	data about Your Game play or Your activity in a Game data about Your activities on the Mobile App and Websites the communications You have with Our and any additional information in those communications in order to provide and improve the Games or Services

RETENTION PERIODS OF PERSONAL DATA

4.1. The duration of Personal data processing depends on the type of service provided and the purpose of processing. As a rule, the data is processed for the duration of the service provision or order processing, until the withdrawal of the expressed consent or filing an effective objection to data processing in cases where the legal basis of data processing is Our legitimate interest.

4.2. The duration of data processing may be extended if the processing is necessary to establish and assert possible claims or to defend against claims, and thereafter only in the case and to the extent required by law. After the end of the processing timespan, the data is irreversibly deleted or anonymized.

4.3. In particular, Your Personal data is processed by Us:

4.3.1. for the purpose of providing You with access to Our Games or providing the Services to You – until You stop playing in particular Game or until the relevant Service is terminated;

4.3.2. for analytical and statistical purposes – until the termination of storage of Your Personal data in connection with another active purpose of processing or until the moment of expressing an effective objection to the processing of Your Personal data (however, no longer than until the last day of the calendar year following the lapse of 6 years since You stopped playing our Games or after the termination of Services);

4.3.3. for the purpose of establishing and asserting claims or defending against claims – until the last day of the calendar year following the expiry of 6 years since You stopped playing our Games or after the termination of Services;

4.3.4. for the purpose of responding to complaints relating to the provision of electronic services and providing a response – until the last day of the calendar year following the expiry of 6 years after the complaint was recognised;

4.3.5. for Our marketing purposes – until Your marketing consent is withdrawn or an effective objection is made to the processing of Personal data;

4.3.6. if the duration of the storage of Your Personal data results from mandatory legal provisions, We will store Your Personal data for the period specified in such provisions.

COOKIES, MOBILE IDENTIFIERS AND SIMILAR TECHNOLOGIES

5.1. We collect information about Your device and how You use our Games or Services, including using cookies or similar technologies and / or mobile identifiers.

5.2. We use cookies or similar technologies and / or mobile identifiers mainly to provide You with our Games once other Services and to improve their quality. You can find detailed information about the cookies or similar technologies and / or mobile identifiers We use in Our Cookies Policy.

5.3. that You can always manage all aspects of data collection and use from Your mobile device or third party application by visiting the “settings” of such application or mobile device or web browser and checking access permissions.

5.4. If You do not want to receive tailored in-application ments from third parties that relate to Your interests on Your mobile device, You may adjust the ad tracking settings on Your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from Your mobile device’s settings, which will prevent continued use of existing behavioural data tied to Your previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), You may be able to apps that offer to provide You with control regarding the collection and use of cross-app data for tailored advertising. All of the opt-in or opt-out tools described in this subsection are provided by third parties, not by us. Huuuge does not control or operate these tools or the choices that rs and others provide through these tools.

5.5. Please note that You may still receive third-party ments in our Games after using these tools, but the advertising You see would not be customized to Your interests or needs.

HUUUGE'S PARTNER LIST

6.1. Huuuge’s Partner List includes a list of trusted advertising network companies with which Huuuge works directly or indirectly, and which may receive your personal data and further process according to their own rules. We encourage you to review the privacy policies of our partners to ensure that you understand their treatment of personal data that they may process. Please note that Huuuge may not directly work or share personal data with all of the companies listed below. From time to time, we may add partners to this list when we make new agreements with partners who are committed to protecting your personal data.

Company Name
Chartboost, Inc.	https://docs.chartboost.com/en/legal/privacy-policy
Tapjoy, Inc.	https://www.is.com/privacy-policy
AdColony, Inc.	https://www.digitalturbine.com/legal/privacy-policy
AppLovin Corporation	https://www.applovin.com/privacy/
Arsus Technologies Ltd (dba ReklamUp)	https://reklamup.com/privacy.php
Adlogic Technology Pte. Ltd	https://www.mintegral.com/en/privacy/
Unity Technologies Finland Oys	https://unity3d.com/legal/privacy-policy
ironSource Ltd.	https://www.is.com/privacy-policy/
Google Ireland Limited	https://policies.google.com/privacy?hl=en-US
Facebook Ireland Limited	https://www.facebook.com/privacy/explanation
Twitter, Inc. (Mopub)	https://www.applovin.com/privacy/
InMobi Pte. Ltd	https://www.inmobi.com/privacy-policy/
OpenX Software Ltd.	https://www.openx.com/privacy-center/ad-exchange-privacy-policy/
Pubmatic, Inc.	https://pubmatic.com/legal/privacy-policy/
Smaato, Inc.	https://www.smaato.com/privacy/
Verizon Media EMEA Limited	https://legal.yahoo.com/us/en/yahoo/privacy/index.html
Fyber Monetization Ltd.	https://www.digitalturbine.com/legal/privacy-policy
HyprMX Mobile LLC	https://www.hyprmx.com/privacy-policy.html
Verve Group, Inc.; VGI CTV, Inc.; Verve Group Europe GmbH	https://verve.com/product-privacy-policies/

WHAT RIGHTS YOU HAVE IN CONNECTION WITH PERSONAL DATA PROCESSING AND HOW YOU CAN EXERCISE THEM?

7.1. You have the right to know what categories of Your Personal data We collect and with who it is shared, access the content of Your Personal data and to request rectification, erasure, restriction of processing, the right to data portability and the right to object to the processing of the data, as well as the right to lodge a complaint with the supervisory authority dealing with the protection of Personal data. The leading protection authority is Polish President of the Office of Data Protection. You may also Your local data protection authority. For more information, please such authority.

7.2. To the extent that Your Personal data are processed on the basis of consent, this consent may be withdrawn at any time.

7.3. You have the right to object to the processing of Your Personal data for marketing purposes if the processing is carried out in connection with Our legitimate interest, as well as – for reasons connected with Your special situation – in other cases where the legal basis of the data processing is Our legitimate interest (e.g., in connection with the analytical and statistical activities).

7.4. Please note that the exercising of the above rights is not unconditional and not feasible in all the cases (e.g. we will not erase Your data if You still play Our Games and those data are necessary to provide You the game services or we will not give You copy of Your data when it infringes other individual’s rights or our trade secrets/ IP). In our response to Your request, we will justify our possible denial of enforcement of Your rights.

7.5. Authorized Agents may act on Your behalf by submitting requests, to protect Your information, we may request that You Your own identity before fulfilling a request submitted by Your agent. Note that since we do not require our s to provide us with names or e-mail addresses, the most certain method to your identity is to submit your request from the Service you are using.

7.6. Additionally, have in mind that in order to execute Your privacy request, Huuuge needs to be sure that it was submitted by the right person. We will have the right to the identity/ request due authentication in order to avoid situation where e.g. we may delete the data of someone else’s .

7.7. You may file a request about exercising Your rights in the following manner:

7.7.1. via Mobile App/ Services or other platforms settings;

alternatively, however, this is subject to the possibilities on verification of our identity (as we normally do not collect e-mails or names of our players)

7.7.2. by letter to the address: Huuuge Games sp. z o.o., Storrady Świętosławy Street 1/501, 71-602 Szczecin, Poland; obligatory attn: Data Protection Officer

7.7.3. by e-mail to the address: [email protected].

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

8.1. We share some of Your Personal data with Your friends and other players that You are playing with to facilitate Your in-game interactions. We may also share Your Personal data with third parties or allow third parties to collect this information from our Games or Services in the manner described below.

8.2. We provide that any third party with whom We share Your Personal data shall provide the same or equal protection of Your Personal data as stated in this .

SERVICE PROVIDERS AND OTHER THIRD PARTIES

8.3. In connection with provision of Games and Services, Your Personal data may be disclosed to external entities, including in particular the payment operator (Stripe Payments Europe, Ltd.), service providers and vendors responsible for maintenance of IT systems, banks, entities providing ing services and entities related to Huuuge, including companies from its group. We may also share Your Personal Data with any other corporate entities within the same corporate group (including parent company and subsidiaries) (“d Entities”) if it is necessary to provide Games and Services. Furthermore:

8.3.1. If You request a refund from the provider of the shop from which you ed the app (e.g. Google, Applovin), or from another external payment provider (like PayPal, Stripe, Appcharge), You agree to allow us to share Your data related to the in-game transaction associated with Your request with that provider. This provider will use Your data to determine whether Your refund request should be approved or denied. The data shared for this purpose will not be used for tracking. For information on how a specific provider processes Your personal data, please refer to their .

8.3.2. If You are using an Apple-branded product and request a refund from the App Store or other Apple services, You agree to allow us to share Your data related to the in-game transaction associated with Your request with Apple. Apple will use Your data to determine whether Your refund request should be approved or denied. The data we share with Apple for this purpose is not used for tracking. Apple uses and protects Your data in accordance with Apple’s .

8.4. Also, upon Your consent, we might use and share Your Personal data with our partners to tailor the ads to Your interests. The list of such partners as well as their privacy policies can be found here. We might update it from time to time.

8.5. In addition, we may share Your Personal data with other third parties or allow them to collect Your information from our Games or Services in some ways not specifically described in this if we have Your consent to do so.

FRIENDS AND OTHER PLAYERS

8.6. Our Games encourage You to interact with other players. In most Games, if You play through a social network or connect to a social network (like Facebook), Your friends who also play our Game will see Your name, photo, player profile and descriptions of Your in-game activity.

8.7. Further, in our Games other players (not being Your friends) will be able to see Your player profile; view descriptions of Your in-game activity; communicate with You within our Games and send You game requests or friend requests through our Games.

SECURITY MEASURES

8.8. We share Your Personal data if necessary for safety, security, or compliance with law. Your Personal data and the contents of all of Your online communications in our Games and between You and Huuuge may be accessed and monitored as needed to provide Our Games and Services and may be disclosed:

8.8.1. to satisfy any laws or regulations that apply;

8.8.2. when we have to disclose the information in response to lawful requests by public authorities;

8.8.3. if Our Games or Services are being used in committing a crime or to share data with other companies and organizations for the purposes of fraud protection and other security precautions;

8.8.4. to protect the rights or property of Huuuge or applicable third parties.

TRANSFER OF DATA

9.1. If You are a resident of EU, note that when You use our Games or Services, Your personal data may be processed outside of the European Countries, for example, to the United States, Israel and possibly other countries. When We transfer, store, and use Personal data collected in the European Countries outside of the European Countries, We comply with our legal obligations and ensure that Your Personal data is subject to suitable safeguards (such as encrypting communication or use of Standard Contractual Clauses) or transferred to “approved” territories (having adequate protection/ equalling to the protection of EU). We are responsible for Your Personal data, and We ensure that We do all our best to protect them!

9.2. As a global company, we may transfer Your personal data to our “d Entities”, located in many countries. When we transfer Your personal data internationally we will take reasonable steps to ensure that Your data is treated securely and lawfully.

9.3. You may direct any questions, concerns or complaints regarding Huuuge’s handling of Personal data or compliance with safeguards related to transfers outside European countries to our Data Protection Officer (see the details in point 13.1. below). If Your complaint still is not resolved through these channels, an additional binding arbitration option may be available to You.

DO WE PROCESS THE PERSONAL DATA OF MINORS?

10.1. Our Games and Services are not intended for underage persons (under the age of majority at the territory of where You are) (“Child” and “Children”) See more in our of Use relevant to the Game or Service You are using. Children are not permitted to use our Games and Services, and We do not knowingly collect any Personal data from Children. We do our best to ensure that We do not collect information from or about Children. If We learn that We have inadvertently gathered Personal data from a Child, We will take measures to respectively enforce our and do not allow such person to play anymore and take reasonable measures to promptly remove the Personal data from our records.

PRIVACY POLICIES OF LINKED THIRD-PARTY SERVICES

11.1 We are not responsible for the ways in which third parties use Your Personal data (other than our partners acting under our guidance). Our Websites and Games may contain ments from third-party services that may link to their own websites or services. If You have any questions about how these entities use Your data, You should review their policies and them directly.

DATA SECURITY

12.1. We comply with international security standards and store Personal data on secure servers. All Personal data shall be treated as confidential information by those who have access to it. In addition, We restrict access to Personal data to only those persons who should have such access. On an ongoing basis, it conducts audits and internal controls to ensure that the measures in place are adequate and ensure compliance with international security standards and internal procedures.

12.2. Where We use security features such as a (or where You use such an option) to access the any Game or any Service, You shall keep such confidential and shall not disclose it to any third party.

12.3. Unfortunately, the transmission of information via Internet links is not completely secure. Thus, although We take the utmost care to protect Your Personal data, it cannot guarantee the security of Personal data transmitted via our Websites or Mobile Apps – any such transmission is at Your risk. When receiving information from You, We make every effort to ensure compliance with procedures and the application of safeguards against unauthorised access.

HOW CAN YOU GET IN TOUCH WITH US?

13.1. We have a Data Protection Officer (the “DPO”), who is the person at Huuuge group responsible for all matters related to data protection and privacy matters. The DPO is the designated for data protection issues for all Huuuge’s companies. You can reach Huuuge’s DPO at the following address:

13.1.1. Data Protection Officer, Huuuge Games sp. z o.o., Storrady Świętosławy 1/501, 71-602 Szczecin, Poland,

13.1.2. [email protected].

13.2. If You have a customer service-related issue, please our Team instead of ing the Data Protection Officer.

13.3. Please be sure to include Your name or Your player ID or address and email address in any correspondence to us so that We can respond to Your inquiry in a timely manner.

U.S. RESIDENTS SUPPLEMENT

14.1. We treat all our s the same. This section, however, specifically provides additional information on how we collect, use, disclose and otherwise process personal information of our players who are individual residents of the United States of America.

14.2. in this section mean the same as they are defined elsewhere in this policy. We refer below to You and it includes our players as well as people who access our Websites or other Services. 

Collecting Personal Information

14.3. Our Services may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”) as specified below.

14.4. Personal information does not include publicly available information, or deidentified or aggregated consumer information.

14.5. We DO NOT (i) sell Your personal information; (ii) knowingly collect, sell or share personal information of s under 13 years of age; (iii) collect, sell, disclose or share sensitive personal information. By sensitive personal information we mean data on race or ethnic origin, religious beliefs, genetic data, biometric data, health data, sexual orientation, philosophical beliefs and the contents of a consumer’s mail, email, text messages that are not directed to us, and personal data from a known child under 13 years of age.

Categories of Personal Information

14.6. We may have collected the following categories of information about You:

Identifiers, for example: real name, alias, postal address, unique personal identifier, online or advertising identifier (ex. device numbers, ADFA, GAAID etc.), IP address, device or WiFi location,
Customer records, for example: mailing address, telephone number, Information defined in Cal. Civ. Code 1798.80(e), for example from the statute: name, address, telephone number,
Protected classifications, for example in the statute: age, gender,
Commercial or Transaction information, for example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies,
Internet or other electronic network activity information, for example browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or ment,
Geolocation data, for example IP address.

Sources

14.7. Our Service obtains the categories of personal information listed above from the following categories of sources:

directly from You, for example, from forms You complete or products and services You purchase,
indirectly from You, for example, from logging Your actions in the game or You’re Your device,
third parties, for example our payment provider or social media.

Business Purposes

14.8. We use the Personal Information collected above for the following business purposes: 

providing Services to s connected with the Services, including improvements and ,
complying with the laws (tax and ing obligations with respect to the Services),
protecting the safety and security of our Services,
protecting Huuuge rights and property in connection with the Services, to enforce the of the Services,
preventing fraud or potentially illegal activities,
managing and delivering marketing activities and some advertising activities,
research & development of the Services (including game and feature development, improvement, optimization and refinement).

Disclosure of Personal Information

14.9. We may share Your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

14.10. We may have shared personal information for a business purpose to the following categories of recipients:

entities within Huuuge Group,
specific professional services providers such as cloud-based software providers, storage providers, security providers, legal advisors,
payment processors/payments services providers,
advertising and marketing partners,
as required by law.

14.11. We do not sell personal information of U.S. players to third parties, regardless of the player’s age. 

Your Rights and choices

14.12. You as a U.S. resident, just as all other s of our Services, have certain rights regarding Your personal information. Details about Your rights and how to perform them are set forth in Section 6 of this policy. Additionally, as a U.S. resident You may have the following rights. Please note that these rights might be subject to certain limitations.

14.13. Your Right to Opt-out of “Sale”/ “Sharing” of Your personal information. We do not currently consider the ways we shared s’ personal information in the past 12 months to comprise the “sale” of personal information.

14.14. Right to Limit Use of Sensitive Personal Information. We do not collect sensitive personal information nor do We use sensitive personal information for the purpose of inferring characteristics about an individual, therefore We do not offer a path to exercise this right.

14.15. Right to opt out of the processing of Your personal information for the purposes of targeted advertising and for profiling in furtherance of decisions, including, solely automated decisions that produce legal or similarly significant effects.

14.16. Right to appeal any decision or indecision related to the exercise of any right granted to You under the applicable law. Instructions for how to submit Your appeal will be included in our response explaining why We denied Your request.

14.17. Right to access. You have the right to confirm whether we are processing Your personal information and access such personal information.

14.18. Right to not be Discriminated: The right to not be discriminated against for exercising these rights. Of course, if You do exercise any of Your rights, We will not treat You any differently.

14.19. Shine the light requests. Customers who are residents of California may request:

a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and
a list of the categories of third parties to whom we disclosed such information.

14.20. How to exercise Your rights. Please see section 13.1. above for detailed description how to us. Inasmuch as the above information is not already provided by Huuuge, Huuuge U.S.-resident s should make any privacy-related request by ing “” from within an app or by ing the DPO using the information in this .

14.21. How to exercise Your rights. Please see section 13.1. above for detailed description how to us. Inasmuch as the above information is not already provided by Huuuge, Huuuge U.S.-resident s should make any privacy-related request by ing “” from within an app or by ing the DPO using the information in this .

14.22. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of receipt. If We require more time (up to another 45 days), We will timely inform You of the reason(s) and extension period in writing. If You have an with us, We will deliver our written response to that . If You do not have an with us, We will deliver our written response electronically. Any disclosures We provide will only cover the 12-month period preceding our receipt of Your request. For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

14.23. Your browser settings may allow You to automatically transmit a “Do Not Track” signal to online services You visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

AMENDMENTS TO THE

15.1. This is verified on an ongoing basis and updated when needed. When the changes will be material, we will notify You and make sure that You have the right not to be bound by them. It may, however, mean that You may no longer use our Games or Services.

Last updated 2023-09-26