Privacy Policy

This Privacy Policy explains how your personal data is collected and processed by ALFADDEL INVESTMENTS LTD ("ALFADDEL INVESTMENTS LTD") when you use our mobile applications (the "App").

The App is a free to play game (with optional in-game-purchases), and in order to maintain the high quality and a great game experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.

We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent.

Collection of information

Information we collect automatically through the app

When you access or use the App, we automatically collect general information about you, including:

• Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times and your IP address.
• Device Information: We collect information about the device you use to access the App, including information about the device manufacture, device model, device's OS, time zone of device, language of device.
• Device identifiers: We collect online identifiers of the device you use to access the App, including IDFA, Google Ads ID, Google Device ID, Game Center ID, Google Play Account ID.
• Usage Information: We collect information relating to your use of the App, including your game progress, scores, achievements and interactions with other players.
• Consumption information: We collect information about your consumption habits relating to your use of the App, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game.

Information we collect from other sources

If you log into the App using a third party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent. You can learn more about how such third-party sites or platforms process your personal data in the relevant privacy policy:

• Facebook: https://www.facebook.com/about/privacy/
• Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/
• Google Play Games: https://policies.google.com/privacy

If you log into the App using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.

Use of information - purpose and legal basis

We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:

Log-, device-, usage-, and consumption information and device identifiers are being processed:

• to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
• to provide and maintain the App and the game experience; and
• to send you technical notices, updates, security alerts, and support and administrative messages;

Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.

• to provide news and information about the App that we think will be of interest to you;
• to personalize and improve the App and provide tailored content and features;
• to monitor and analyze trends, usage and activities in connection with the App;

Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").

• to provide users that have given us consent to share their advertising IDs with our ad network partners (as further specified under "Sharing of Information") for the purpose of serving them with personalized advertisement in the App (behavioral advertising).

Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR.

Information from other sources are being processed:

• to provide and deliver the products and services you request and send you related information; (Performance of contract, Section 6(1)(b) of GDPR)
• to link or combine information we get from others to help understand your needs and provide you with better service; and
• to provide news and information about the App we think will be of interest to you; (Legitimate interests, Article 6(1)(f) of GDPR)

We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

Storage of information

ALFADDEL INVESTMENTS LTD will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules. Your personal data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with ALFADDEL INVESTMENTS LTD has ceased.

Sharing of information

We disclose information about you to the following categories of recipients based on the legal bases under Sections 6(1)(b) 6(1)(c) and 6(1)(f) of the GDPR:

• Social networks, see more under "Social Sharing features";
• Third parties if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of ALFADDEL INVESTMENTS LTD or others;
• Other players in order to provide certain in-app features, such as leaderboards, if you log into the App using a third-party service;

Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your Device identifiers to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:

• MoPub, Inc.
• Facebook, Inc.
• Google LLC
• Unity Technologies
• IronSource
• Applovin Corporation
• Vungle, Inc.
• ByteDance Ltd. (TikTok)
• Amazon.com, Inc.
• Fyber
• MobFox US LLC
• TapJoy, Inc
• Snapchat (Snap Inc.)
• Tencent Holding Ltd.

In connection with our processing, we use following data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers:

• Tenjin, Inc.
• Facebook Analytics
• Firebase (Google LLC)
• Appfigures

Social sharing features

The App offers or can offer social sharing features and other integrated tools (such as the Facebook "Like" button), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the App.

Children

Use of the App is limited to users aged 13 years and above, except in European Economic Area, where the App is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or 16, depends what is applicable) or more years old.

If you have additional questions about ALFADDEL INVESTMENTS LTD's privacy practices related to children under the applicable minimum age, please contact us at contact@alfaddelinvestments.com.

Transfer to third countries

In connection with the processing, we will in certain circumstances transfer your personal data to recipients outside the EEU. We only transfer personal data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Privacy Policy and applicable law (e.g., Privacy Shield or EU Standard Contractual Clauses).

Security

ALFADDEL INVESTMENTS LTD takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Push notifications

We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

Sale of Personal Data (CCPA)

ALFADDEL INVESTMENTS LTD does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, we do not sell your data. However, we have disclosed some categories of personal data to third parties for business purposes. To the extent this practice is interpreted to constitute a "sale" under the CCPA, please contact us to exercise your right to withdraw consent.

YOUR RIGHTS

Rights of EEU residents

• Right to request access: You have the right to request access into the data that we are processing on you (Article 15 GDPR).
• The right to object: You have the right to object to our processing of your personal data on grounds relating to your particular situation (Article 21 GDPR).
• Right to rectification: You have the right to have inaccurate personal data rectified (Article 16 GDPR).
• The right to restriction: You have the right to obtain restriction of processing in certain circumstances (Article 18 GDPR).
• The right to withdraw consent: If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time (Article 7 GDPR).
• The right to data portability: You have the right to receive the personal data you have provided us in a structured format (Article 20 GDPR).

Rights of California residents (CCPA)

• Right to opt out: Each California resident can request any business stops selling personal information to third parties.
• Right to be informed: You have a right to be informed about what categories of personal data we are collecting.
• Right to disclosure: You can request us to disclose what personal data we have collected on you in the past 12 months.
• Right to deletion: You can request us to delete the personal data we have collected on you in the past 12 months.
• Right to equal services and prices: We will not discriminate against you for exercising any of your CCPA rights.

How to exercise my rights

If you wish to use any of the rights described above, you may contact us at any time by emailing us at contact@alfaddelinvestments.com.

Mandatory verification: We will need to verify your identity before processing your request.