PRIVACY POLICY

Genius Sonority– Privacy policy

Last modified: August 2021

1. Introduction

Genius Sonority Inc. ("Genius Sonority," "we," "us," "our," or "our") develops and operates games for the web and mobile environments ("Games"), as well as web and mobile applications for playing Games on multiple devices and platforms (each, an "App"). We respect your privacy.

We respect your privacy and are committed to making our practices regarding your data more transparent and fair. This Privacy Policy explains how we collect, store, use, and share your personal data, and how we use it to protect your privacy whenever you visit our sites, install our apps, play our games, interact with us, or otherwise access or use our services. This policy applies whenever you visit our site, install our apps, play our games, interact with us, or otherwise access or use our services.

We encourage you to read this Privacy Policy to ensure that you fully understand and agree to it. In accordance with this Privacy Policy, you have the right to terminate your use of the Service at any time. If you do not agree to this Privacy Policy, please discontinue the Service and avoid using the Service.

You are not legally required to provide any personal data, without which we cannot provide you with the full range of services or the best possible experience.

2. Data Collection

We collect the following four types of data (we consider it "personal data" to the extent that it allows for the identification of certain individuals or is linked to such potentially identifying data):

2.1 Data automatically collected or generated:

When someone visits, uses, or interacts with our Services, we may collect or generate technical data about them. We collect or generate such data independently or through the use of third party services, including through the use of "cookies" and other tracking technologies.

In most cases, we use such data to better understand how our users typically use and interact with the Services. By using such technical and device data, we can help us and our partners deliver interest-based or more effective advertising and content, optimize our ad management and user experience, and improve the overall performance and user experience of our Services. and improve the overall performance and user experience of our Services.

2.2 Data received from Google, and other channels:

Once you connect the Games to your Google, Facebook, Apple or similar account, we will receive access to your public profile, including, as applicable, your full name, gender, photo, time zone, and a list of your friends playing the Games. In addition, we or our advertising partners may receive from Google and our other marketing channels general information concerning the performance of our advertising campaigns, such as the targeted age group or interests, and we or our partners may be able to link such general data to any other data in our possession.

If you access our Services through a third party such as Google, Facebook or Apple or connect our Services to any third party account, you should also read their terms and conditions and privacy policies. If you are unclear about what information a third party application is sharing with us, please visit that third party application's website in order to learn more about their privacy practices.

2.3 Data received from you:

You may provide us with Personal Data voluntarily, such as when you set up an account with us, contact us, when you provide us with your e-mail address, when you participate in promotions, when you place any purchases in any of our Games, when you post on our public forums or groups, when you interact with other users through the in-game chat or when you choose to connect your Google, Facebook Apple or similar account to any of our Games.

2.4 Transaction Data:

In-Game purchases will typically be processed by the relevant platform provider such as Apple, Google or Facebook, and we will not collect or store your financial data such as your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to the purchase, such as your name, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.

3. Uses of Date

3.1 We generally use your Personal Data as follows:

"Performance of a contract" – We will use this basis for processing necessary to make the Games, and to send you service communications, gifts and awards.

“Consent” –We will process your Personal Data based on your consent.

"Compliance with a legal obligation" – In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation, or if we receive an order from a court or regulatory body.

"Legitimate interests" – We will process your Personal Data based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Games and through other channels, matching users to create in-game friends lists, improving our customer service and support operations, fraud detection and protecting and securing our users, ourselves and our Services.

3.2 The purposes for which we use Personal Data are described in more detail below:

To facilitate, operate, and provide our Services;

To authenticate the identity of our players, and allow them access to additional features;

To provide our users with customer care, assistance and technical support services;

To enable you to interact with other players in the game;

To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;

To manage and deliver advertisements more effectively, including contextual, behavioral and interests-based advertising based on in-Games progress and activity, based on your preferences or other data available to us or to our business partners, including for re-targeting purposes;

To contact our users with general or personalized service-related messages to contact our users with promotional messages and to facilitate, sponsor and offer certain events and promotions;

To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;

To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective Services; and

To comply with any applicable laws and regulations.

4．Aggregated and analytical information

We may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they may use their own cookies to provide their service.

We use the standard analytics tools of Google Analytics and we may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies.

We use anonymous, statistical or aggregated information and may share it with our partners or Service Providers for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you.

5. Uses for Advertisements

Our Games include advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads.

The ads we or our advertising partners deliver may be shown within our Games, our Services, or through other channels, such as third party websites and applications.

Any information you provide to sites, applications or services advertised through our Services will be covered by their applicable privacy policies specified therein. Please be sure to read the privacy policies of any third party applications, services and sites that you visit or provide permission to access your information. It is those third parties’ responsibility to protect any information you give them, so we will not be held liable for their use of your personally identifying information.

6. Storage and Retention of Date

Your Personal Data may be maintained, accessed, processed and stored by Genius Sonority and our authorized affiliates, Service Providers and business partners in and from the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Genius Sonority has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction. Where we transfer Personal Data of UK or EEA users to countries outside the UK or EEA which are not considered by the UK authorities or European Commission to offer adequate protection, we generally make such transfers subject to approved data transfer agreements, such as the Standard Contractual Clauses.

We retain your Personal Data in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will take reasonable measures to delete your Personal Data if you delete your account. We may also retain your Personal Data for legal and accounting purposes, in accordance with our Data Retention Policy. If you have any questions about our Data Retention Policy, please contact us at coingalaxy@ap-gs.com.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.

7. Data Sharing

We may share your data with certain third parties, including law enforcement agencies, our Service Providers and our affiliates. The main circumstances in which we share data are summarized below:

7.1 Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order, or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

7.2 Service Providers and Business Partners: We may engage selected third party companies, contractors and individuals to perform services complementary to our own. These may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only use it for such purposes.

7.3 Third Party Integrations: The Services allow you integrate with certain third party services, such as in order to connect your Google, Facebook or Apple account to a certain Game, Login with Google, Facebook or sign in with Apple or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.

7.4 Protecting Rights and Safety: We may share your Personal Data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Genius Sonority, any of our users or any members of the general public.

For the avoidance of doubt, Genius Sonority may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.

8. Cookies and Automated Information Collection Technologies

Like many websites, Genius Sonority, our Service Providers and other parties may send cookies to your device when you access or view the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes. Information contained in a cookie may be linked to Personal Data. We use cookies for purposes such as improving the quality of the Services, tailoring recommendations to interests, and making the Services easier to use.

Third party advertisers on the Services may also use, place, or read cookies or other technologies as described below on your device, and those practices are subject to their own policies. For more information on how you can opt-out of or disable cookies, please see the Data Subject Rights (Section 11) below.

We and our Service Providers may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively by excluding our current players from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-game preferences, and speed up load times.

We, our Service Providers, and other parties may collect the following information via cookies and other technologies:

(1) the type of device you are using;

(2) your device’s operating system and version;

(3) your mobile device’s identifiers, like your MAC Address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);

(4) your browser type;

(5) your browser language;

(6) referring and exit pages and URLs;

(7) platform type;

(8) the number of clicks on a page or feature;

(9) domain names;

(10) landing pages;

(11) pages viewed and the order of those pages;

(12) the amount of time spent on particular pages;

(13) game state and the date and time of activity on our websites or Games.

In some cases, we will connect this information with your social network ID or Genius Sonority user ID.

On our Services, we may use Google Analytics or other vendors to collect information about your behavior and demographics. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners. You can opt out of Google’s collection and processing of data by going to https://tools.google.com/dlpage/gaoptout.

9. Communications

We may contact you with important information regarding our Services. For example, we may notify you of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.

If you have signed up to receive such communications from us, we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

You have the right to withdraw your consent to receiving such promotional communications at any time. You can do this by e-mailing us at coingalaxy@ap-gs.com.

10. Security of Data

In order to protect your Personal Data held with us and our Service Providers, we use industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.

11. Data Subject Rights

In case we process Personal Data about you,

(1) You have the right to know what Personal Data we maintain about you.

(2) You may, at any time, access, correct, request deletion, request restriction of our processing of your Personal Data or object to the processing of your Personal Data, as set by applicable law. Please note that if you ask us to delete or restrict how we use or process your Personal Data, subject to applicable law, we may not be able to provide you with all of our Services and customer support or the quality of the Services may be diminished.

(3) You may ask to transfer your Personal Data in accordance with your right to data portability.

(4) You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.

If you exercise one (or more) of the above-mentioned rights in accordance with the provisions of applicable law, or any other right that you may have under applicable law, we will, to the extent required, instruct third parties that hold your Personal Data, in accordance with this Privacy Policy, to act accordingly.

If you wish to manage the information we receive about you from a third party application or platform where you play our Games, such as Google, Facebook, or Apple, please follow the third party application’s instructions for updating your information and changing your privacy settings.

12. Age eligibility

All Games and Services are available only to individuals who are the greater than or equal to eighteen (18) years of age or the age of legal majority in your jurisdiction.

We reserve the right to request proof of age or parental consent at any stage. We may block users whom we suspect are under the applicable age. We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services or playing any of our Games, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such minor.

If you believe that we might have any such Personal Data, please contact us at coingalaxy@ap-gs.com.

13. Updates; How to Contact Us

Updates and amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. After this notice period, all amendments shall be deemed accepted by you. If you do not agree to be bound by the terms of the new or modified Privacy Policy, you are required to stop using the Services.

Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your Privacy, please contact us at coingalaxy@ap-gs.com.

14. Controlling Version

The Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English language version, the meaning of the English language version shall prevail. Where an addendum to this Privacy Policy applies to a specific geographical region, that addendum will control the application of this Privacy Policy for all users in the specified region.