INTRODUCTION

This Privacy Policy describes why and how we collect and use your personal data and informs you of the right and choices you have about your personal data which you provide, or we collect in connection with our game services and our practices. Your use of game services distributed by Mofun Entertainment Limited (“Mofun Games”, “we” or “us”) involves our collection and processing of your personal data. It is important for you to understand how this happens and how you may control it. And by accessing our websites ,using our services and clicking “Agree” button on the pop-up window, you acknowledge that you have read, understood, and accepted the following terms. In the case you do not agree to any of the terms, you may immediately stop using our services.

According to the GDPR, COPPA and other applicable laws and regulations, the minimum age for you to play our game unsupervised is 13 (in United States of America)/ 14(in United Kingdom)/13-16(in European Union, may differ from different countries)/18(in most countries) years old. We will not knowingly collect personal data from children under this age. Insofar as certain countries apply a higher age of consent for the collection of personal data, We requires parental consent before an Account is created for children and personal data associated with it collected, and use all reasonable efforts to verify that the consent was given by the child’s parents or legal representative, considering available technologies. We encourage parents to instruct their children to never give out personal data when online.

In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you or your guardian in advance, your personal data may transfer to the successor of Mofun Games.

We may periodically modify, adjust, or revise the terms of this privacy policy. You are encouraged to check this page from time to time to ensure that you are informed of any changes. The updated terms especially material changes relating to your rights as a data subject will be announced to you before you use our service, in the form of a pop-up window with check boxes or otherwise to obtain your consent again. You agree to check the new terms regularly.

1. What Data We Collect

(1) Data you provide to us

l Contact Information (such as email address)

l Account registration or registration for using the game services (such as user name, password ）

l Other data you choose to give us (such as data to identify a lost account)

(2) Data we collect automatically

l Data about your account, game progress and any use of game services

l IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)

l Cookies and similar technologies (see more below)

(3) Data we collect from our partners

l Data we receive if you link a third-party application with the Service (such as Facebook)

l Data to fight cheating and fraud (such as click fraud in advertising)

l Data for advertising and analytics purposes, so we can provide you with a better Service (with your consent)

l General location data (with your consent)

l Precise geo-location data (GPS, with your consent)

(4) Cookies and similar technologies

Like most online services, we and our partners use cookies and similar technologies to analyze the using behavior for the purpose of providing and personalizing the Service, exhibiting target advertisements and preventing fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

2. Why Do We Collect Your Personal Data

(1) To make sure the Service work properly and smoothly

To perform the contract, we process necessary data to

l create accounts in order to allow you to play our games and use our Services

l operate the Game and Services

l communicate with you about Service-related issues or information

Legal basis: such data collection and processing are strictly necessary for the performance of the contract, i.e., the service(s) operation.

(2) To make the Service more suitable for our players

In order to provide a constantly optimized Service to our players, we have a legitimate interest to collect and process necessary data to

l Set up and update player profiles

l Develop and improve the Service as well as the user experience

l Manage our relationship

l Customize your Service experience

l Respond to your comments ,questions, and provide you with technical support

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

l Send you related information, such as updates, security alerts, and support messages

Legal basis: our data collection and processing activities in this section are based on our legitimate interest. Mofun Games only processes or shares personal data collected through game services for analytics purposes where we have a legitimate interest and it does not outweigh the rights of users.

(3) To show personalized advertisements. (optional)

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

l improve advertising and other marketing and promotional activities; and/or

l deliver, target, and improve our advertising activities.

Legal basis: our data collection and processing activities in this section are also based on subjects’ express consent.

For all data processing activities that rely on users’ consent, you can withdraw your consent at any time through the contact methods listed in Section 8 of this Privacy Policy. As soon as we receive your notice to withdraw your consent and complete our identification process, we will delete your data correspondingly, unless applicable law or regulations state otherwise or we have legitimate reasons to retain your data. You acknowledge that with the deletion of data, some additional services may not be available for you.

3. Who May Access Your Personal Data

In addition to Mofun Games and/or its affiliates, other parties may also access your personal data in the following situations. You or your parents acknowledge and agree that you or your parents have foreseen and agreed to such disclosure when you provide your personal data.

(1) Competent Authorities

We may provide certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients for example our users or a specific segment of the public when we reasonably think it is necessary to protect us or other people.

In addition, as required by applicable laws, we reserve the right to disclose your personal data in the cases that we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, for example, if (a) you are violating any agreements between us, such as the Terms of Service and this Privacy Policy or otherwise damage us, and the disclosure of this information is necessary to resolve these disputes through judicial process; (b) you are infringing third parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud, crimes or other illegal activities.

(2) Third-Party Contractors

Mofun Games works with a number of (if any) social media contractors, advertising services contractors, data analyzing contractors, payment contractors, fraud-detection contractors and other third-party contractors on or through our services. We do not sell your personal data and only share non-personally identifiable, aggregated, and public data with third parties.

Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. For example, users purchasing products or services will be required to provide additional data to third party payment contractors, such as a valid credit card number, expiration date, etc. Such third-party payment contractors may collect, process, retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries.

Please be aware that we cannot control the activities of such third parties, and we cannot guarantee that they adhere to the same privacy policy as we do. Since those contractors may access your data as data controller and operate under their own privacy policies (usually provided on their official websites), we strongly encourage you to check their privacy policies on their official websites and learn more about their data processing practices.

the list of third party ：

Admob

Purpose of collecting personal data: provide advertising service in mobile game

Official Website: https://admob.google.com/home/

AppsFlyer

Purpose of collecting personal data: provide advertising analysis service in mobile game

Official Website: https://www.appsflyer.com/

Applovin

Purpose of collecting personal data: provide advertising analysis service in mobile game

Official Website: https://www.applovin.com/

Bugly

Purpose of collecting personal data: resolve abnormalitie in mobile game

Official Website: https://bugly.qq.com/v2/

Firebase

Purpose of collecting personal data: provide advertising analysis service in mobile game

Official Website: https://firebase.google.com/?hl=zh-cn

Facebook

Purpose of collecting personal data: provide advertising service in mobile game

Official Website: https://www.facebook.com/

Google

Purpose of collecting personal data: provide advertising service in mobile game

Official Website: https://www.google.com/

IronSource

Purpose of collecting personal data: provide advertising service in mobile game

Official Website: https://www.ironsrc.com/

Unity

Purpose of collecting personal data: provide advertising service in mobile game

Official Website: https://unity.com/

Vungle

Purpose of collecting personal data: provide advertising service in mobile game

Official Website: https://vungle.com/

Pangle

Purpose of collecting personal data: provide advertising service in mobile game

Official Website: https://www.pangleglobal.com

Mintegral

Purpose of collecting personal data: provide advertising service in mobile game

Official Website: https://www.mintegral.com

4. Data Retention

We will store and retain your data for as long as possible until this Agreement terminates or is deleted at your request.

The user data we collected above is stored and encrypted in our servers located in United States of America(“USA”) or HongKong.

In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between us.

Please note that the removal or deletion of any of your data may result to the termination of some of our applicable services.

We will only store your information for as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by applicable law. After that your personal data will be deleted, blocked, or anonymized, as required by applicable law.

5. International Data Transfers

As Mofun Games is a global network with our subsidiaries and affiliates located around the world, your personal data may be transferred to and stored outside the country or region where you are located. Mofun Games, our subsidiaries and affiliates may use servers and other resources in various countries and territories to process your information. Because different countries may have different data protection laws than your own country, we will take steps to ensure that your personal information is adequately protected within the locations of our servers. For example, we may ask for your consent before transfer personal information across borders, and to implement security measures such as data de-identification prior to cross-border data transfer.

We may transfer your personal data to a third party that acquires all or substantially all of us or our business. We may also disclose your personal data to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with any other business, in which case we may disclose your personal data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

If you are visiting the Services from the European Union or other regions with laws governing data collection and use, please note that your personal data is transferred to USA or HongKong. USA and HongKong do not have the same data protection laws as the EU and will not afford many of the rights conferred upon data subjects in the EU. By clicking the “agree” on the pop-up window in our service when loginning in, we have your or your parents’ consent to:

• use your personal data for the purposes listed in Section 2 of this Privacy Policy; and

• transfer your personal data to USA or HongKong as indicated above;

If there are changes involving data transfer information, we will use a pop-up window to obtain your consent again.

6. Security of Your Personal Data

We are committed to continuing the improvement of our technical measures in order to maintain the privacy and integrity of your personal data no matter where it is stored. Mofun Games and its affiliates have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal data will remain subject to our technical and organizational controls and our policies (including this Privacy Policy).

We will do our best to protect your personal data, and will rely on you to select secure passwords, to protect those passwords, and to use appropriate security software on your devices.

Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you and this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal data.

7. Your Rights

If you request in writing (e.g. through E-mail), we will provide you a copy of your personal data in an electronic format after passing our verification process. You also have the right to correct or modify your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. Also, you may always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings or contact us according to the methods listed in Section 8 of this Privacy Policy.

Pertaining to the marketing or promotional communications, you may opt-out of receiving such communications in accordance with the instructions therein. You can make a request for the rights below, but only twice within 12 months (California resident).

(1) Right of Access (or Right to Know About Personal Information Collected, Disclosed, or Sold)

You have the right to access your personal data that we hold about you, i.e., the right to require free of charge (i) information about whether your personal data is retained, (ii) access to and/or (iii) duplicates of the personal data retained. You can use the right to access to your personal data through the Privacy Dashboard or contact us. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.

(2) Right to Rectification

If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you can change the information you provided via the Privacy Dashboard or contact us using the methods listed in Section 8.

(3) Right to Erasure(or Right to Request Deletion of Personal Information)

You have the right to request the deletion of personal data concerning you if the reason why we could collect it (see section 2. above) does not exist anymore or if there is another legal ground for its deletion.

As a result of deleting all your personal data, you will lose access to our services including game-related information linked to your account. You should clearly know that once your personal data is deleted, with today’s technology, we cannot restore it.

(4) Right to Object

When our processing of your personal data is based on legitimate interests according this Privacy Policy, you have the right to object to this processing . If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as stipulated by applicable laws; in particular, if the data is necessary for the establishment, executions or defense of legal claims. You also have the right to lodge a complaint at a supervisory authority.

(5) Right to Restrict the Processing of Your Personal Data

You have the right to obtain restriction of processing of your personal data where one of the following applies: (a) the accuracy of the personal data is contested by you; (b) the processing is unlawful and you oppose the deletion of the personal data and requests the restriction of its use instead; (c)other cases stipulated by applicable laws.

(6) Right to Data Portability

You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions stipulated by applicable laws. Mofun Games makes your personal data available in structured HTML format through the Privacy Dashboard as described above.

(7) Right to Opt-Out of the Sale of Personal Information (if you are California residents)

You can opt-out of the sale of your personal information through this “Do Not Sell My Personal Information” Link: https://mofungame.com/opt. We will respect your choice, reply to your request in 15 days after verification, and will not ask for your consent to sell your personal information at least in the next 12 months.

To exercise any of these rights, please contact us at privacy@mofungame.com

*For EU residents, we will respond to such requests without undue delay and generally within one month (this may be extended by two further months in certain circumstances).

*For California residents, we will provide you with information about how we plan to reply to your requests in ten working days, and take actions to reply to your request in 45 days (which can be extended to another 45 days if necessary).

*For Brazil residents, we will respond to your requests concerning right to access in 15 days, and other requests immediately. In case an immediate response is not possible, we will inform you of the reasons that prevent the immediate adoption of the measure.

We may ask you to provide further information or complete a form in connection with the request for the identity verification, and you acknowledge that if you refuse to provide necessary information, we will not be able to reply to your requests.

We will work with third parties to which we have transferred your personal data as appropriate to fulfill your request. We may not be able to fulfill requests that would interfere with rights of others(e.g.where providing personal data would reveal information about another person) or our rights (e.g.where we have an independent basis for processing, or the information includes our trade secrets or intellectual property).

* If there are special provisions provided by applicable laws (including but not limited to GDPR, CCPA, CPRA, COPPA, LGPD, etc.), we will process your personal data in accordance with local applicable laws.

8. Contact and Complaints

Mofun Games is the data controller under this Privacy Policy, and If you have questions or wish to make a complaint about how we process your personal data, please contact our Data Protection Officer through following methods:

E-mails: privacy@mofungame.com

and we will endeavor to deal with your request as soon as possible.

*If you are California residents, we will rectify our behaviors in 30 days upon receiving your verified complaints, or you are entitled to bring a lawsuit against us.

According to applicable laws, you may also have the right to complain to data protection authorities in the country in which you live or work.

9. Changes

If we make any material changes to this policy, we will post the updated policy here and notify our users.

Effective Date：Marth 21, 2023